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.
Connect with Parag:
Free Strategy Session
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
Reviews
Rahul Sharma ★★★★★
Parag provided both professional and personal advice in a super timely manner. Would definitely recommend and work with again in the future.
Nicholas Visco ★★★★★
Extremely knowledgeable and well versed in probate matter. Mr. Patel and his team have been excellent to work with.Latest Blog Posts
Live Webinar on U.S.-India Tax Planning: Key Issues, Tax Treaties: Limited Free Registrations Available
I am pleased to announce that I will be speaking in an upcoming Strafford live video webinar, U.S.-India Tax Planning: Key Issues, Tax Treaties on Monday, December 16, from 1:00pm-2:30pm EST. Our panel will provide tax counsel and advisers with a thorough and practical guide into the tax reporting requirements and planning opportuni…
New IRS Form Simplifies Section 83(b) Election for Restricted Stock
Understanding the Section 83(b) Election Employees who receive restricted stock or other property for their services often face a complex tax situation. Typically, income tax is due when the stock vests, meaning when the employee gains full ownership rights. However, a Section 83(b) election allows employees to pay taxes upfront, base…
Taxpayer Wins Form 5471 Penalty Case
In the case of Mukhi v. Commissioner (163 T.C. No. 8, November 18, 2024), the U.S. Tax Court ruled that the IRS lacks the authority under Code Section 6038(b)(1) to impose an assessment for failure to file Form 547
Analysis of the Revised Form 14457: Key Changes to the IRS Voluntary Disclosure Practice
The IRS’s updates to Form 14457, “Voluntary Disclosure Practice Preclearance and Application,” mark a significant tightening of the program’s requirements and an intensification of its focus on enforcement. These changes, including a new willfulness admission, stricter timelines for document submission, and mandatory full payment of liabilities, demand careful consideration by taxpayers and…
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.