The Risks of “Opting Out” of OVDI

- By : Parag Patel

Under the 2011 OVDI voluntary disclosure program, the penalties for failing to timely file Foreign Bank Account Reports, (FBAR’s) and the penalties for failure to file information returns (such as…

Happy Birthday Streamlined Filing Compliance Procedure!

- By : Parag Patel

…the disclosure of foreign assets. SFCP has two sub-programs: one for US residents (Streamlined Domestic Offshore Procedures or “SDOP”) and one for non-US residents (Streamlined Foreign Offshore Procedures or “SFOP”)….

New Post-OVDP IRS Voluntary Disclosure Procedures Announced

- By : Parag Patel

…Filing Compliance Procedures (for non-willful taxpayers). Hence, taxpayers with offshore accounts who did not commit any tax or tax-related crimes and do not need the voluntary disclosure practice to seek…

Swiss Banks’ Deadline to Disclose Information is Extended

- By : Parag Patel

…in the IRS Off-shore Voluntary Disclosure Program (OVDP) or seek to correct tax noncompliance through other avenues. The OVDPoffers an incentive for delinquent tax payers to disclose their offshore accounts….

Republican Party Rallies Against FATCA: Success Unlikely

- By : Parag Patel

…platform, according to the RNC. Approved in 2010 after a tax-avoidance scandal involving a Swiss bank, FATCA requires most foreign banks and investment funds to report to the U.S. Internal…

Permanent annual automatic extensions granted for FBARs to October 15

- By : Parag Patel

The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced last week that, to implement the new due date for FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR),…

New Jersey Transfer Inheritance Tax : How the Tax Works

- By : Parag Patel

…Forms Some assets (real estate, stocks and bank accounts) require the written consent of the director of the New Jersey Division of Taxation before they can be transferred. This consent…

Letter to Your Spouse

- By : Parag Patel

…these benefits. Personal financial statement. Attached to this letter is an updated personal financial statement that is a bit more detailed in describing the stocks, real estate, partnerships, bank accounts

US Supreme Court to Rule on FBAR Penalties Case

- By : Parag Patel

The debate over FBAR penalties for non-willful failure to disclose all of an individual’s or business’ foreign bank accounts has reached the Supreme Court. The issue is whether the maximum…

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…

FBAR Deadline Automatic Extension

- By : Parag Patel

…an interest in or signatory authority over foreign bank and financial accounts holding $10,000 or more at any time during the year must independently identify and report these interests to…

Correcting Common FBAR Errors

- By : Parag Patel

accounts during the eight-year period. The penalty is increased to 50 percent if the IRS or DOJ has initiated an investigation of the financial institution in which the accounts are…

Trinidad and Tobago and the United States sign new agreement to exchange of information under FATCA

- By : Parag Patel

…unexpected (and the worst) in their tax treatment and disclosure of offshore assets. Patel Law Offices has consulted with hundreds of clients regarding their offshore asset compliance issues. Patel Law…

No More Delays for FATCA: Get Ready for Disclosure

- By : Parag Patel

…just soon, it’s imminent.” Our law office, which represents many taxpayers throughout the U.S. and around the world with undisclosed offshore accounts, believes that FATCA is a game-changer in international…

Argue for No Penalty and a Warning Letter for FBAR Violations

- By : Parag Patel

The IRS may send a warning letter in lieu of asserting penalties for failure to file a Form TD F 90-22.1, “Report of Foreign Bank and Financial Accounts,” if it…

IRS Reminds U.S. citizens and dual citizens about U.S. filing requirements

- By : Parag Patel

…requirements, including Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR). No new developments are provided, only reminders of existing laws and regulations. Some dual-citizen taxpayers may…

Protective Filing of Information Returns

- By : Parag Patel

accounts that exceed $10,000 in the aggregate in value at any time during the year. If you have any foreign bank accounts, this also has to be disclosed on Part…

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

- By : Parag Patel

…foreign financial accounts and assets. The streamlined procedures require the filing of original or amended tax returns reporting whatever foreign source income was generated in each of the applicable tax…

Form 8938, FATCA, FBAR and penalties for all (including bankers)

- By : Parag Patel

…assets. FATCA created Form 8938, an additional foreign account reporting requirement over and above the Report of Foreign Bank and Financial Accounts (FBAR) or Form TD F 90-22.1 that needs…

IRS FBAR Penalties Are Now Unmitigated

- By : Parag Patel

The Internal Revenue Service will no longer reduce the penalty for taxpayers who non willfully fail to file Reports of Foreign Bank and Financial Accounts (FBAR or FinCen 114), according…

FBAR Deadline is June 28, 2013

- By : Parag Patel

This month we remind taxpayers of the upcoming June 30, 2013 deadline for filing Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), to report financial interests…

FBAR Deadline Slightly Extended

- By : Parag Patel

After a misworded posting caused confusion about the 2020 deadline to file FBARs (i.e., FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR)), Treasury’s Financial Crimes Enforcement Network…

Beware PODs and TODs

- By : Parag Patel

Virtually any bank or brokerage account can provide that it is paid on death (“POD”) or transferred on death (“TOD”) to named beneficiaries. And IRAs, 401Ks, pension plans and insurance…

Foreign Account Tax Compliance Act (FATCA) online registration program is launched

- By : Parag Patel

banks, investment funds and insurance companies to report to the IRS Americans’ offshore accounts worth more than $50,000. It was enacted after a Swiss banking scandal showed U.S. taxpayers hid…

Delinquent FinCen Form 114 (FBAR) Filings

- By : admin

…in order to provide a meaningful way for non-willful taxpayers to remedy past non-compliance with respect to non-U.S. bank accounts and income associated with those accounts. Read this article. Warning…

Uncertainty About The Future Of The Gift And Estate Tax Laws Will Continue

- By : Parag Patel

…Death” Accounts: Often, a person will own assets such as bank accounts with a child as joint tenants with right of survivorship as a means of providing the child with…

Beware of Overlooked Common Overseas Tax Forms

- By : Parag Patel

…foreign financial accounts that exceed $10,000 in the aggregate in value at any time during the year. If you have any foreign bank accounts, this also has to be disclosed…

Estate Planning Checklist

- By : Parag Patel

…___________________ ___________________________________________________________ ___________________________________________________________ 4. Cash, cash deposits, and cash equivalents: State the name and address of each bank or institution and who owns each item. (a) Checking accounts, including money…

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

- By : Parag Patel

…send their information reports on financial accounts held by U.S. persons to the IRS under the Foreign Account Tax Compliance Act (FATCA) or pursuant to the terms of an intergovernmental…

Upcoming live video webinar: U.S.-India Tax Planning: Reporting Issues, Traps to Avoid, Tax Treaties, FTC, FACTA/FBAR Reporting, Passive Income

- By : Parag Patel

…tax-exempt earnings in India are tax-exempt in the U.S. Earnings from these accounts must be identified and included on the individual tax return. In addition, practitioners must understand the tax…