How Long is the Tax Fraud Statute of Limitations?
...indefinite or unlimited fraud statute refers to civil tax fraud, not criminal tax matters. The IRS basically has unlimited time to audit you for civil fraud. But due to the...
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The Taxpaper Roadmap (seriously?)
The Taxpaper Roadmap was recently created by The Taxpayer Advocate Service, an independent organization within the IRS. This map illustrates, at a very high level, the stages of a taxpayer’s...
New Portability Election Extension Prevents Lost Estate Tax Exemption
...As always, however, it is important for married couples to seek guidance from their estate planning attorney to determine what tax planning techniques are best suited to their particular needs....
What I learned at the 2022 National Institute on Criminal Tax Fraud and Tax Controversy in Las Vegas
I just returned from the American Bar Association Section of Taxation’s annual National Institute on Criminal Tax Fraud and Tax Controversy in Las Vegas, which is the largest gathering of...
Parag Patel Esq. was a featured speaker at the National Association of Enrolled Agents (NAEA) International Tax Certificate Program
...international taxation for tax professionals. Mr. Patel discussed the tax laws affecting the tax issues surrounding foreign tax topics for foreigners with US income and US residents with foreign income....
New IRS FBAR Practice Unit
The IRS LB&I recently issued its Practice Unit on FBARs. Practice Units are “job aids” and training materials intended to describe for IRS agents helpful practices about tax concepts in...
Do Inherited Foreign Assets Receive a Step-up in Cost Basis for U.S. Tax Purposes?
...related to cost-basis for inherited non-U.S. assets. What is a “step-up” in cost basis at death? Under current U.S. tax law, the income tax basis of inherited assets is updated...
Forms 5471, 5472, 3520 Partial Penalty Relief Still Available for 2019 and 2020 Returns
IRS Notice 2022-36 provided relief for certain taxpayers from certain failure to file penalties and certain international information return penalties with respect to tax returns for tax years 2019 and...
Parag Patel Esq. speaks at New Jersey Society of Certified Public Accountants (NJCPA) Annual Tax Seminar: “A New Foreign Frontier: Foreign Income & Asset Reporting Update”.
...reported, and the potential liability of the taxpayer and tax preparer. We will discuss solutions for non-compliant taxpayers. Experienced tax attorney Parag Patel has handled hundreds of foreign asset disclosures...
IRS Announces Increased 2023 Gift Tax Annual Exclusion, Gift, and Estate Tax Exemptions
The Internal Revenue Service recently released the annual inflation adjustments for tax year 2023, which include welcome increases for wealth transfer tax planning. The gift tax annual exclusion will increase...
Parag Patel Esq. speaks at New Jersey Society of Certified Public Accountants (NJCPA) Annual Tax Seminar: “2022 Federal Tax Update and Latest Tax Controversy Hot Topics”.
...tax controversy. We will explore tax collection developments, penalty developments, new voluntary disclosure programs, the latest IRS audit campaign initiatives, and other hot topics in tax controversy. The New Jersey...
Wash Sale Benefits for Cryto Investors
...regulation set by the Internal Revenue Service that prevents a taxpayer from deducting losses relating to a wash sale. By having this regulation in place, taxpayers are not able to...