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…

No More Delays for FATCA: Get Ready for Disclosure

- By : Parag Patel

…risk steep penalties. Foreign financial institutions with U.S. customers who do not enter into reporting agreements with the Internal Revenue Service will face a 30 percent withholding on U.S. income…

New Mandatory E-filing Form 8300 for Reporting of Large Cash Currency Transactions

- By : Parag Patel

…than $10,000, the person must file another Form 8300. Large penalties apply in case of failure to timely file: The penalty for negligent failure to timely file, to include all…

Another Bank Discloses Accountholders: Credit Suisse to Turn Over U.S. Account Data

- By : Parag Patel

…of Americans who have secret accounts. Those people who have had their accounts disclosed will be subject to civil tax penalties by the IRS and potential prosecution by the Justice…

US DOJ Tax Asst Attorney General Keneally Reports that One third of Swiss Banks Joining US DOJ Swiss Bank Program

- By : Parag Patel

…can receive amnesty from criminal prosecution for their previously unreported offshore bank accounts in exchange for filing amended tax returns and FBARs, and paying all back taxes, interest, and penalties….

HSBC India Customer New Indictment Uncovers More HSBC Details

- By : Parag Patel

…(VDP) program, which remains in effect after OVDI’s expiration, for protection against civil (and criminal) penalties. Patel Law Offices is a law firm dedicated to helping clients resolve complicated tax,…

Employee or Contractor?: The IRS’s New Voluntary Classification Settlement Program (VCSP)

- By : Parag Patel

…interest charges or penalties, and the IRS won’t audit you on payroll taxes related to these workers for prior years. You must prospectively switch them to employee status and agree…

Swiss Bank Disclosure Round Up

- By : Parag Patel

…coming weeks, as Switzerland’s cherished bank secrecy slowly gets wound back. The program requires the banks to hand over some previously hidden information and face penalties equivalent to up to…

IRS Publicizes and Celebrates OVDI Success

- By : Parag Patel

…not yet include penalties. “By any measure, we are in the middle of an unprecedented period for our global international tax enforcement efforts,” said IRS Commissioner Doug Shulman. “We have…

Traveling? Resolve Tax Debt Before Getting Your Passport

- By : Parag Patel

…urgent need for a passport. A taxpayer with a seriously delinquent tax debt is generally someone who owes the IRS more than $52,000 in back taxes, penalties and interest for…

More Swiss Banks Agree to Cooperate with the IRS

- By : Parag Patel

…of the year to sign up to the program, which requires the firms to hand out some previously hidden information and face penalties of up to 50 percent of assets…

Financial Crimes Enforcement Network (FINCEN) Issue Final Rules

- By : Parag Patel

…a period of five years. The FBAR has become a difficult and comprehensive reporting requirement for individuals with foreign accounts. The penalties for failuer to file an FBAR are extrememly…

FATCAts

- By : Parag Patel

…FATCA and taxpayer reporting. There are stiff penalties for non-compliance and HNW clients, who often have complex structures, will need to ensure they comply with all applicable reporting obligations. The…

U.S. Signs FATCA Pacts with Malta, Netherlands, Bermuda, Jersey, Guernsey and Isle of Man

- By : Parag Patel

…to report on the holdings of U.S. taxpayers to the Internal Revenue Service or face heavy penalties. The law has sparked controversy abroad, with foreign banks and U.S. expatriates and…

How To Limit An Executor’s Personal Liability For A Decedent’s Unpaid Taxes

- By : Parag Patel

…the tax liability. Request a Prompt Assessment (IRS Form 4810). Code § 6501(d) permits executors to request a prompt assessment of income and gift taxes, including penalties, owed by the…

New Online System for Filing Your Report of Foreign Bank and Financial Accounts (FBAR)

- By : Parag Patel

…voluntary disclosure under the IRS’s Offshore Voluntary Disclosure Initiative (OVDI) and avoid or decrease penalties. The OVDI is open until August 31, 2011. FinCEN said it can only accept FBAR…

Start 2021 with a few New Year’s tax planning resolutions

- By : Parag Patel

…high civil and criminal penalties. New Year’s is always been a time of making resolutions. However, there are few of us who make tax planning New Year’s resolutions. Do not…

More Swiss Banks Agree to Disclose US Customers Accounts: Expect More Customer Letters to be Sent

- By : Parag Patel

…little choice. Swiss regulators have publicly signaled to banks that it may be better to pay penalties now than risk separate action by the Justice Department. Banks that participate will…

Make Sure You have Filed FATCA Compliance Certifications

- By : Parag Patel

…over US$10,000 in aggregate. The IRS has established several amnesty programs, under which a non-compliant individual can become compliant and avoid potentially high penalties or criminal prosecution. However these amnesty…

From Hong Kong With Love…

- By : Parag Patel

…funds later should not require a Form 3520 filing. W strongly recommend US tax legal counsel to guide US persons with such issues to avoid Form 3520 ccomplications (and penalties)….

Latest Guilty Plea for an Another HSBC Offshore Bank Accountholder

- By : Parag Patel

…he had an interest in a financial account in HSBC Bank Bermuda. He further admitted that for tax years 2003 through 2008, he prepared, signed under penalties of perjury, and…

An Ill-advised IRS Streamlined Filing Compliance Procedure Filing

- By : Parag Patel

…returns, failing to pay millions of dollars of taxes and submitting a false offshore compliance filing with the IRS in an attempt to avoid substantial penalties and criminal prosecution. According…

FBAR Reforms Recommended

- By : Parag Patel

…already and non-compliance penalties are extreme. We recommend some additional penalty reform recommendations, especially for non-willful cases (currently there is a $10,000 per account per year penalty). We believe most…

Probate of Estates in New Jersey

- By : Parag Patel

…deadlines, severe penalties and interest may apply. If you do not have all the information available in time, you can file for an extension and pay your best estimate of…

The IRS has woken up.

- By : Parag Patel

…$50,000 in tax while close to 2,000 taxpayers owe more than $1 million. In addition to the taxes, delinquent taxpayers will be subject to late payment and late filing penalties….

The IRS’ Complex Statute of Limitations

- By : Parag Patel

…does not run is if a taxpayer does not sign their return or if they alter the “penalties of perjury” language at the bottom of the return. For tax collection,…

2007 Year-End Tax Planning Tips

- By : Parag Patel

…this will result in a 5 percent tax on the gain, instead of a 15 percent rate if the sale is postponed until 2008. Reducing underpayment penalties Those facing a…

How Will the IRS Find Out By Your Foreign Account? Let’s Count the Dozens of Ways

- By : Parag Patel

…advice of a tax legal professional. Failure to do so can result in significant civil penalties or a referral for criminal tax prosecution. Patel Law Offices can explain your legal…

IRS announces new Streamlined Filing Compliance Procedures

- By : Parag Patel

…terms (qualifications, penalties, etc.) whenever it chooses. Moreover, in certain situations the IRS is permitting taxpayers already in the OVDP to either adopt the rules of the new OVDP or…

Educational Panel Discussion: The U.S. Government’s Global Crackdown on Tax Evasion: Where It Has Been and Where It Is Going

- By : Parag Patel

…taxpayers with exposure to potential criminal liability and/or substantial civil penalties due to a willful failure to report foreign financial assets and pay all tax due in respect of those…