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Is First-Time Abatement Applicable In International Penalty Cases?

26 January, 2024

The Internal Revenue Service (IRS) issued a memorandum from John E. Hinding, the Director of Specialized Examination Programs & Referrals, regarding penalty abatements for Forms 5471 and 5472. The memo was addressed to IRS Independent

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National Taxpayer Advocate calls IRS Penalties Draconian and Inefficient

19 January, 2024

National Taxpayer Advocate Erin Collins recently issued her 2023 Annual Report to Congress. By law, the Advocate’s report is required to identify the 10 most serious problems taxpayers are experiencing in their dealings with the IRS

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Crypto is not = Cash currency for IRS reporting

17 January, 2024

The IRS released Announcement 2024-4, providing transitional guidance under section 6050I with respect to reporting transactions involving the receipt of digital currency. Generally, when receiving more than $10,000, IRS reporting is required. The announcement clarifies that, at

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Interesting 2023 Foreign Account Cases

17 January, 2024

Foreign Account/FBAR confusion: In Kurotaki v. United States, 132 AFTR2d 2023-6138, a Hawaii federal district court determined that a U.S. green card holder who lived in Japan and spoke no English did not willfully fail

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Fantastic Recommendations for Form 3520

15 January, 2024

The American Institute of CPAs (AICPA) recently sent excellent recommendations to the Internal Revenue Service (IRS) against the IRS’ systemic assessment of penalties for late-filed Forms 3520, Annual Return To Report Transactions With Foreign Trusts

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The New IRS ERC Voluntary Disclosure Program

10 January, 2024

The IRS ERC Voluntary Disclosure Program provides a special resolution opportunity for employers with erroneous or excessive ERC claims. The IRS recognizes that many erroneous or excessive ERC claims are partly due to aggressive marketing

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AICPA Makes Useful Recommendations For International Forms 3520/3520

2 January, 2024

The American Institute of CPAs (AICPA) submitted comment letters to the IRS requesting improvements be made to two international tax returns pertaining to foreign trusts. The AICPA requested that the IRS update, add to, and

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New IRS Voluntary Disclosure Program lets employers who received questionable Employee Retention Credits pay them back

24 December, 2023

This week, the IRS announced a new ERC voluntary disclosure program (ERCVDP) that has many distinctive features: Our firm has filed hundreds of IRS voluntary disclosure submissions over the years, and there are numerous similarities

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Parag Patel Esq. Speaks at NJCPA Seminar on”Employee Retention Credit Audit Issues: Surviving IRS Scrutiny”

20 December, 2023

Parag Patel Esq. was a featured speaker at a New Jersey Society of Certified Public Accountants (NJCPA) Seminar entitled “Employee Retention Credit Audit Issues: Surviving IRS Scrutiny”. You may email our office to receive the

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The IRS’s First-Time Abatement (FTA) Penalty Waiver

19 December, 2023

There are currently more than 160 penalties contained in the US tax code. There is a penalty for nearly every possible reporting, filing, and payment requirement failure.  While penalties have long been a component of Federal

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Parag Patel Esq. Speaks at NJCPA Seminar on”The Corporate Transparency Act: What You Need To Know”

16 December, 2023

Parag Patel Esq. was a featured speaker at a New Jersey Society of Certified Public Accountants (NJCPA) Seminar entitled “The Corporate Transparency Act: What You Need To Know”. You may email our office to receive

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ERC Disallowance Letters 105C Sent to Taxpayers

7 December, 2023

The IRS has notified over 20,000 taxpayers via IRS Letter 105C (Disallowance of Claim) that their claims for the employee retention credit are being disallowed because entities either did not exist or did not have

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Recent Posts

  • Parag Patel Esq. speaker at the National Association of Enrolled Agents (NAEA) Seminar “2025 Mid-Year Update”September 1, 2025
  • The Complex Landscape of FBAR and Foreign Asset Reporting: A Critical Webinar Update for Tax Professionals (Free)August 31, 2025
  • The Department of Justice’s Focus on Employment Tax CrimesAugust 29, 2025
  • Dr. Sriram Case: A Summary of Key Tax and Legal IssuesAugust 28, 2025
  • All Things Appeals Webinar: A Strategic Guide for Tax ProfessionalsAugust 26, 2025

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