The Top 10 Form 8621
There are many common problems that can be avoided.
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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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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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Latest Blog Posts
New FATCA / CRS reporting penalties in India
The new 2023 Tax Budget in India has many new proposals. However, the most important proposal for investors, especially non-resident Indians, is a new penalty for providing inaccurate information for KYC (Know Your Customer) including information provided in FATCA and CRS questionnaire. The new budget proposes a penalty of Rs.5,00…
65 Day Election on March 6, 2023
Trustees and executors have the ability to make certain elections on, or before, March 6, 2023 that could affect 2022 tax returns of the trusts and estates for which they are fiduciaries, as well as the returns of the beneficiaries of those trusts and estates. Trusts and estates generally pay higher…
High Penalties for failure to file an FBAR: Not Really Enforced (yet)?
U.S. persons, including U.S. citizens, residents, corporations and estates, must report certain foreign financial accounts, including bank accounts, brokerage accounts and saving accounts to the U.S. Treasury department each year. If the aggregate value of the foreign financial accounts exceeded $10,000 at any time during the year, a ‘Foreign Bank Acco…
IRS Audits of Millionaires Remain Very Low
The Internal Revenue Service still rarely audits millionaires, according to a new report published by Syracuse University’s Transactional Records Access Clearinghouse. Despite calls to ramp up scrutiny of high-net-worth individuals’ tax returns and wealthy tax evaders and a legislative push for increased funding for the agency, the likelihood of a milli…
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
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
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.
Submission Procedure (DFSP)
8 Penaltie s
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
U.S. owners and investors of certain foreign corporations must
file a Form 547