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 provided both professional and personal advice in a super timely manner. Would definitely recommend and work with again in the future.
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Extremely knowledgeable and well versed in probate matter. Mr. Patel and his team have been excellent to work with.Latest Blog Posts
Late Disclosure of Foreign Gift for Wedding Results in Penalty
The ongoing litigation over the Internal Revenue Service’s administrative authority to assess international information-return penalties has entered a new phase. For the past few years, the tax community has closely monitored structural challenges to the Service’s penalty powers, particularly following the high-profile litigation concerning Section 6038. However, a major decision issued …
Kwong: Preserving Client Claims for COVID-Era Penalty and Interest Refunds
The U.S. Court of Federal Claims recently issued a landmark ruling in Kwong v. United States, 179 Fed. Cl. 382 (2025), that profoundly alters the landscape of Internal Revenue Service (IRS) compliance enforcement for the pandemic era. For tax practitioners, this decision exposes a massive vulnerability in how the IRS assessed failure-to-file penalties, failure-…
Internal Revenue Service’s Clarification on Reasonable Cause for Form 5472 Penalties
In an era of intensified international tax penalty enforcement, advising foreign-owned domestic corporations requires absolute precision. Among the most punitive enforcement mechanisms in the Internal Revenue Code is the Form 5472 filing requirement under Section 6038A and Section 6038C. A single unfiled or incomplete form carries an automatic $25,000 initial penalty, making …
Defending the Cross-Border Client: Join Parag at the NJSEA Annual Conference This June
The boundary between civil tax non-compliance and criminal tax exposure has never been more porous. As the Internal Revenue Service aggressively expands its enforcement footprint utilizing advanced data analytics, practitioners must be prepared to handle both complex international compliance structures and high-stakes criminal investigations. For tax professionals, staying ahead of these s…
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.