Common Problems Solved – Patel Law Offices

Streamlined Domestic Offshore Procedures (SDOP)

The Streamlined Domestic Offshore Procedures is one of the two popular programs available under the IRS Streamlined Filing Compliance Procedures. It is for U.S. Resident Taxpayers who originally filed income tax returns, but were non-willful in not reporting foreign accounts, investments or income, who can use Form 14654 Certification by U.S. Person Residing in the U.S. to become compliant. This limited tax amnesty solution for U.S. resident taxpayers holding noncompliant foreign accounts has a reduced single year 5% offshore penalty. Our legal team has advised and prepared hundreds of Streamlined cases with the IRS.

Streamlined Foreign Offshore Procedures (SFOP)

The Streamlined Foreign Offshore Procedures is one of the two popular programs available under the IRS Streamlined Filing Compliance Procedures. Applicants need not have filed original tax returns, but they must be non-willful in not reporting foreign accounts, investments or income, via Form 14653 Certification by U.S. Person Residing Outside of the U.S. to become compliant. This limited tax amnesty solution for U.S. non-resident taxpayers holding noncompliant foreign accounts has a 0% penalty. Our legal team has advised and prepared hundreds of Streamlined cases with the IRS.

Delinquent International Informational Return Submission Procedures (DIIRSP)

The DIIRSP is one of the four methods for taxpayers with unreported offshore accounts to become compliant. Taxpayers who have failed to file certain international-related information returns including Forms 5471, 8938, 3520, 8865, 926, 5472, an 8858 can use the DIIRSP to cure the non-compliance. No penalties are applied if there is reasonable cause for the failure to file the information form and the IRS agrees. Reasonable Cause is a fact specific submission, which is based on each applicant's facts and circumstances.

Delinquent FBAR Submission Procedure (DFSP)

The FBAR is the FinCEN Form 114, which is commonly misunderstood. A delinquent or late FBAR is subject to very high penalties. The DFSP is one of the four methods for taxpayers with unreported offshore accounts to become compliant. Taxpayers who have failed to an FBAR can use the DFSP to cure the non-compliance. While there is no DFSP penalty the DFSP has complex rigid eligibility requirements. Our legal team mitigates foreign account FBAR mistakes for clients around the globe.

Form 8938 Penalties

A delinquent or late Form 8938 Statement of Foreign Financial Assets is subject to many common mistakes and high penalties. Our legal team cures many common Form 8938 errors for clients around the globe.

Form 5471 Penalties

U.S. owners and investors of certain foreign corporations must file a Form 5471, otherwise there are very high Form 5471 Penalties. Form 5471 is a complex form with many common mistakes. because of the expansive disclosure of corporation's assets, liabilities and equity. Our legal team can help you fix late or unfiled Form 5471 errors.

Malta Pension Plan Problems

Malta Pension Plans have been criminally and civilly investigated by the IRS and are on the IRS "dirty dozen" list. Recently in late 2021, the United States and Malta entered an agreement regarding Malta pension rollovers. We have assisted dozens of taxpayers with compliance and solutions with Malta Pension Plan problems.

Form 3520 Penalties

U.S. persons connected to foreign trusts or US recipients of foreign gifts must file a Form 3520, otherwise there are very high Form 3520 penalties. Form 3520 is a complex form with many common mistakes. Our legal team can help you fix late or unfiled Form 3520 errors.