Internal Revenue Service announces new International Data Exchange Service: The Beginning of Information Sharing

- By : Parag Patel

The Internal Revenue Service announced this week the opening of the International Data Exchange Service (IDES) for enrollment. Financial institutions and host country tax authorities will use IDES to securely…

Large Penalties: Form 5471 Information Return of U.S. Persons With Respect to Certain Foreign Corporations

- By : Parag Patel

…penalty assessments and the percentage of taxpayers granted abatements trending downward, taxpayers and their tax advisors will need to increase their awareness of the potential for international tax penalties and…

US FATCA Enforcement Softens due to Coronavirus

- By : Parag Patel

…with hundreds of clients regarding their offshore asset compliance issues. Patel Law Offices is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems….

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

- By : Parag Patel

taxpayer is eligible for the relief, this should reduce the administrative burdens and related costs tied to filing these forms. Taxpayers will still have to research and review each account…

The IRS is Assessing Form 3520 Foreign Information Reporting Penalties

- By : Parag Patel

…of clients regarding their tax compliance issues. Patel Law Offices is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm assists…

IRS gives widespread penalty relief: ACTION REQUIRED

- By : Parag Patel

…1120-F, 1120-FSC, 1120-H, 1120-L, 1120-ND, 1120-PC, 1120-POL, 1120-REIT, 1120-RIC, 1120-S and 1120-SF) Exempt organization tax returns: Form 990-T (unrelated business income tax); Form 990-PF (excise tax payments on investment income)…

IRS Notices for OVDI Program

- By : Parag Patel

…firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm assists (and defends) clients and their advisors to legally disclose (and legitimize) foreign accounts….

IRS’ Takes Legal Action Against Offshore HSBC Indian Accounts

- By : Parag Patel

…U.S. taxpayers have opened bank accounts with HSBC India since 2002. Federal law requires U.S. taxpayers to pay federal income taxes on all income earned worldwide. U.S. taxpayers must also…

Opting-out of the Offshore Voluntary Disclosure Initiative: FBAR Penalty Mitigation Guidelines

- By : Parag Patel

…is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm assists (and defends) clients and their advisors to legally disclose (and…

Appeals of penalties imposed during the Offshore Voluntary Opt-Out

- By : Parag Patel

When a taxpayer has a tax increase though a civil tax audit (or examination, in IRS terminology), a taxpayer has the right to appeal that increase administratively and through court,…

IRS Official Announces New Focus on Offshore Assets in Indian Banks

- By : Parag Patel

…a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm assists (and defends) clients and their advisors to legally disclose (and legitimize)…

IRS Releases New IRS Form W8-BEN: U.S. persons beware of completing such form at the request of a third party

- By : Parag Patel

…you’re one of the few taxpayers required by the IRS to fill out Forms W-8, you would be well-served to consult an experience US tax professional with international tax experience….

Quiet or Silent Disclosure Commentary from the Government Accountability Office

- By : Parag Patel

…regarding their offshore compliance issues, including Quiet Disclosures. Patel Law Offices is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm…

The “Quiet” or “Silent” Disclosure

- By : Parag Patel

…attorney. For additional information, contact Patel Law Offices at 732-623-9800. Patel Law Offices is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems….

HSBC India Customer New Indictment Uncovers More HSBC Details

- By : Parag Patel

…firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm assists (and defends) clients and their advisors to legally disclose (and legitimize) foreign accounts….

Beware IRS Letter 6291

- By : Parag Patel

…firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm assists (and defends) clients and their advisors to legally disclose (and legitimize) foreign assets….

Analysis: IRS New Disclosure Program

- By : Parag Patel

…referrals and to resolve their civil tax and penalty obligations on a standardized framework. The new procedures continue to provide taxpayers an ability to come into tax compliance and generally…

New Jersey inheritance tax

- By : Parag Patel

…the tax. •An inheritance tax return, Form IT-R for residents or Form IT-NR for nonresidents, must be filed and the tax paid within eight months after the decedent’s death. •While…

Estate Tax in 2010

- By : Parag Patel

…gift tax, there will be a $1 million lifetime gift tax exemption and an annual gift tax exclusion of $13,000 per donee. Rates on gift tax also rise in 2011…

Pre-immigration estate planning

- By : Parag Patel

…for US gift and estate tax purposes. Pre-immigration estate tax planning in this context means pre-domiciliary estate planning. Because of the limited scope of the US gift tax in the…

What Client Tax Advisors Should Do About the New Corporate Transparency Act

- By : Parag Patel

…Network (FinCEN). Compliance Implications for Tax & Accounting Professionals: Understanding and adapting to the CTA is crucial for tax & accounting firms and Certified Public Accountants (CPAs) due to potential…

Using the 65-day rule as an opportunity for income tax savings for estate

- By : Parag Patel

…and 39.6%, similar to individuals. The critical difference between estates and individuals is that estates reach the maximum tax bracket of 39.6% once their taxable income is over $12,400, compared…

Pennsylvania’s 2010 Tax Amnesty Program

- By : Parag Patel

…penalties and half of the interest for anyone who pays his/her delinquent state taxes. What Taxes Are Eligible for Amnesty? All taxes administered by the PA Department of Revenue are…

Is First-Time Abatement Applicable In International Penalty Cases?

- By : Parag Patel

…pay, or deposit. The FTA procedure aims to reward taxpayers with a history of tax compliance by granting them relief from the consequences of a one-time error. Beyond domestic taxpayers,…

Obama to Keep 2009 Estate Tax Level

- By : Parag Patel

Last week the Wall Street Journal reported that President Obama will likely freeze the current estate tax level to $3.5 million which is the estate tax exemption amount for 2009….

What FATCA Means to You and Your Investments

- By : Parag Patel

…TO PREVENT TAX EVASION The US requires its taxpayers to disclose all global income. Under FATCA, the US government mandates foreign financial institutions to get customers’ personal, tax and residency…

Tax Relief for Strategic Investments

- By : Parag Patel

…the credit is first applied to the taxpayer’s New Jersey Gross Income Tax liability. Any excess is refunded. For corporate business investors, if the tax credit amount exceeds the taxpayer’s…

US Taxation of Foreign trusts: Foreign grantor trust

- By : Parag Patel

tax rules. “Foreign” (i.e., non-U.S.) means that the trust is not considered a U.S. domestic trust, so neither the trust nor its trustees are not liable to U.S. taxation. “Grantor”…

Silent Disclosure: The Qualified Amended Return (QAR)

- By : Parag Patel

…income tax return. The general rule is that taxpayers are stuck with a position once they take it on a tax return filed the IRS. However, there is one obscure…

$3.5 Million Federal Estate Tax Exemption for 2009 Could Mean Higher State Death Taxes

- By : Parag Patel

…imposed a death tax equal to the federal credit decoupled their tax systems from the federal tax system, and began to impose a stand-alone death tax. Many states now only…