Correcting Common Form 8621 Errors
The US government has solutions to correct common Form 8621The Top 10 Form 8621 Problem s
There are many common problems that can be avoided.
Meet Mr. Patel
Mr. Patel’s expertise is in all stages of tax controversies including international tax
law, foreign bank account
Mr. Patel is a graduate of Georgetown (J.D.) and New York University (LL.M tax) law schools, which are the top 2 tax law schools in the United States. Mr. Patel is a Board Certified Tax Law Attorney, Board Certified Estate Planning Law Specialist, Board Certified Elder Law Attorney, and frequent speaker on legal issues affecting tax, offshore tax planning, and estate planning.
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About Us
Patel Law Offices’ goal is to achieve our clients’ objectives in the most creative, responsive, and cost-effective manner.
Our International Tax Attorney team represents clients nationwide and globally in IRS offshore and voluntary disclosure solutions. We have counseled clients in over 1000 voluntary disclosure matters and are one of the most experienced IRS offshore and voluntary disclosure law firms.
Each case is led by Mr. Patel, who is a Board Certified Tax Law Lawyer. Our International Tax Attorney team concentrates in IRS offshore and voluntary disclosure solutions for undisclosed accounts, assets and investments including Streamlined Domestic Offshore Procedures (SDOP), Streamlined Foreign Offshore Procedures (SFOP), Voluntary Disclosure Practice (VDP), Delinquent International Information Return Submission Procedure (DIIRSP), Delinquent FBAR
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Parag is very knowledgeable and professional. He responded quickly to questions and for scheduling appointments. We have had documents prepared for our business as well as estate planning for our family. I highly recommend his services, his guidance was very beneficial to our family both legally and financially.Latest Blog Posts
IRS Quietly Changes its Voluntary Disclosure Practice For the Worse
The IRS’s Voluntary Disclosure Practice (VDP) allows noncompliant taxpayers who have failed to meet their tax obligations to come into compliance and avoid criminal prosecution. Financially, the VDP offers the benefit of reduced penalties compared to those imposed through audits or criminal investigations, helping taxpayers resolve liabilities more predictably and possib…
Check cashing N.J. construction company owner pleads guilty to tax evasion
Last week, the owner of a local construction company in New Jersey admitted he cheated the IRS out of about $1.35 million in taxes. Alain Rodrigues, 49, of Old Bridge evaded taxes and filed false returns when he deposited only a portion of customers’ payments into a business bank account…
New IRS Voluntary disclosure program for employee retention credit
On August 15, 2024, the IRS introduced a second voluntary disclosure agreement (VDA) program targeting companies that have claimed the employee retention credit (ERC) as provided by the CARES Act. Businesses that may have received ERC refunds based on improper claims should consider participating in this VDA program before the IRS ident…
US Supreme Court Will Favor Taxpayer Challenges to the IRS
The US Supreme Court’s recent reversal of the Chevron doctrine in the Loper Bright Enterprises v. Raimondo case has significant implications for disputed tax matters. Here are some of the key potential impacts: Overall, the reversal of the Chevron doctrine represents a significant shift in the balance of power between fed…
Common Problems Solved
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 accoun
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 accoun
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
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 893
Form 5471 Penalties
U.S. owners and investors of certain foreign corporations must
file a Form 547
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.