IRS Reduces Administrative Burden (for the first time) of Filing Some Forms 3520 and/or Forms 3520-A

- By : Parag Patel

…Foreign Bank and Financial Accounts (FBAR). Taxpayers who have not filed to file any such international forms should seek competent legal counsel immediately to avoid or reduce the high penalty…

Another Local New Jersey client of HSBC India Pleads Guilty

- By : Parag Patel

…of Foreign Bank and Financial Accounts, (FBARs), for 2005 through 2008. As part of his plea agreement, Gupta has agreed to pay a one-time FBAR penalty of $259,045. The tax…

2011 Offshore Voluntary Disclosure Initiative Frequently Asked Questions (FAQs) and Answers

- By : Parag Patel

…the statute of limitations for assessing tax (including tax penalties) and to assess FBAR penalties. For additional information, contact Parag Patel of Patel Law Offices at 732-623-9800 or visit us…

Run to the Door: IRS Terminates Offshore Voluntary Disclosure Program (OVDP) effective September 28, 2018

- By : Parag Patel

…addressing previous failures to comply with U.S. tax and information return obligations with respect to those assets: IRS-Criminal Investigation Voluntary Disclosure Program; Streamlined Filing Compliance Procedures; Delinquent FBAR submission procedures;…

IRS Collects $10 Billion From Voluntary Disclosures of Foreign Assets

- By : Parag Patel

…Report of Foreign Bank and Financial Accounts, also known as the FBAR. The IRS recently revised the certification forms used for the streamlined procedures. The most current versions of Forms…

IRS’ Takes Legal Action Against Offshore HSBC Indian Accounts

- By : Parag Patel

…back taxes and interest, as well as accuracy-related penalties. Under the regular FBAR rules, a taxpayer could pay up to 50% of the highest amount in each account for each…

HSBC Client Pleads Guilty to Conspiring to Hide Indian Accounts From IRS

- By : Parag Patel

…of foreign bank or financial account (FBAR) relating to his undeclared bank accounts for the calendar years 2004-2009, during which the accounts had the highest balance. We expect that HSBC…

Another U.S. taxpayer with an offshore HSBC bank account pleads guilty

- By : Parag Patel

…tax returns, false amended tax returns, and false FBARs. According to court documents, Ms. Bhasin of Huntington, NY, filed a false individual income tax return for 2008 that failed to…

IRS Announces “Good Faith” 90 Day Extension of Voluntary Disclosure Deadline

- By : Parag Patel

…of time to assess tax (including tax penalties) and to assess penalties for failure to file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR). Requests for…

Opting-out or Opting-in of OVDI

- By : Parag Patel

…a much smaller FBAR penalty than the OVDI program’s 25% penalty. If the taxpayer shows the violation was due to reasonable cause, there might be no penalty at all. However,…

One Month Countdown: The Deadline is Nearing for U.S. Taxpayers with Undisclosed Accounts to Come Forward

- By : Parag Patel

…failure to file an FBAR can be as high as $100,000 or 50% of the account balance for each violation, whichever is greater. It could also result in criminal penalties…

New Extended Deadline for OVDI

- By : Parag Patel

…Account (FBAR), in prior years to report a foreign bank account or signature authority over a foreign bank account owned by an employer. Similar is permitted for delinquent Form 5471,…

HSBC India Customer New Indictment Uncovers More HSBC Details

- By : Parag Patel

…or India address,” according to the indictment. “He wants a HOLD on all his accounts.” If convicted, Ahuja, faces as long as 10 years in prison on the FBAR charges,…

Analysis of the new 2012 Offshore Voluntary Disclosure Program (OVDP)

- By : Parag Patel

…failure to file the delinquent FBARs if there were no underreported tax liabilities and the FBARs were filed by August 31, 2010 (FAQ 17). Presumedly, the IRS will follow the…

IRS Announces new OVDP Declines-Withdrawals Campaign

- By : Parag Patel

…program. We have seen more audits and FBAR inquiries associated with taxpayers who have not come forward. Taxpayers should know whether they have Federal tax return issues, or anticipated issues,…

HSBC customer Josephine Bhasin Criminal Sentencing Very Light

- By : Parag Patel

…the Justice Department’s Tax Division on July 15, 2010, she filed a false Report of Foreign Bank and Financial Accounts (FBAR) for 2009 and a false amended tax return for…

Benefits and consequences of entering or failing to enter the Offshore Voluntary Disclosure Initiative program

- By : Parag Patel

…in Federal prison Extremely high civil tax and FBAR penalties Loss of professional licenses Immigration consequences such possible deportation or failure to re-enter U.S. Time lost away from family and…

IRS announces an update to its Voluntary Disclosure Practice Preclearance Request and Application

- By : Parag Patel

…for federal income tax purposes, received previously untaxed funds, or was required to be reported on an information return or report (e.g., Form 8938 or FBAR) and was not reported….

Top myths of US tax compliance for Foreign Accountholders

- By : Parag Patel

…has major penalties. However, the IRS has modified one of its amnesty programs, the Streamlined Offshore Filing Procedures, to eliminate late filing and FBAR (Foreign Bank Account Report) penalties. Under…

IRS Form 8938 and the Offshore Voluntary Disclosure Program (OVDP)

- By : Parag Patel

…was not opened in the tax year, implicitly (and affirmatively by omission) states that account was opened in a prior year. As a result, prior years FBARs should have been…

Rare confluence of tax law and immigration law

- By : Parag Patel

…Reports of Foreign Bank and Financial Accounts (FBARs) and naturalization fraud. According to the indictment, Gatta was born in Chile and became a naturalized U.S. Citizen in 2012. The indictment…

2012 Offshore Account Criminal Tax Cases

- By : Parag Patel

…of Foreign Bank and Financial Accounts (FBARs) for those same years. Rusch was arrested the previous day by U.S. law enforcement agents in Miami after being removed from Panama by…

U.S. Taxpayers at New Risk of Audit from OVDP Declines and Withdrawals Campaign

- By : Parag Patel

…Financial Accounts (FBARs). One of TIGTAs findings was that the IRS had not followed up on a number of non-compliant taxpayers who requested participation in OVDP, but were either denied…

Below is a List of Common Forms Applicable in Compliance Requirements for U.S. Citizens and Residents with Foreign Assets, Trusts, and Entities

- By : Parag Patel

Foreign Financial Assets FinCEN Form 105 Report of International Transportation of Currency or Monetary Instruments FinCEN Form 114 Report of Foreign Bank and Financial Accounts (FBAR) Form 8938 Statement of…

India Expected to Sign FATCA Agreement Tomorrow

- By : Parag Patel

…help to the IRS means that no foreign account is secret. U.S. persons must report worldwide income and most must file IRS Form 8938 and Foreign Bank Account Reports (FBAR)…

Taxpayer’s Beware: Proving Non-Willful Conduct in the new IRS Streamlined Filing Compliance Procedures

- By : Parag Patel

…of the law.” Furthermore the taxpayer must “provide specific reasons for your failure to report all income, pay all tax, and submit all required information returns, including FBARs. If you…

How to Demonstrate Non-Willfulness Under The Streamlined Filing Compliance Procedures

- By : Parag Patel

…all income, pay all tax, and submit all required information returns, including FBARs. People who are considering opting for the more lenient, streamlined program must be aware of the meaning…

Another HSBC Customer Likely Going to Jail

- By : Parag Patel

…a Milwaukee neurosurgeon, Arvind Ahuja, of filing a false tax return and failing to file a Report of Foreign Bank and Financial Accounts, or FBAR, related to HSBC accounts in…

Citizenship renunciation fee increases as American expatriates flee FATCA

- By : Parag Patel

…OVDP program and Delinquent FBAR Submission Procedures and Delinquent International Information Return Submission Procedures. Sources Wall Street Journal Money News Forbes Federal Register (PDF file) US State Department STEP News…

Consequences of Filing False Streamlined Filings

- By : Parag Patel

…failure to report all income, pay all tax, and submit all required information returns, such as FBARs, was due to non-willful conduct. If convicted, Booker faces a maximum sentence of…