About – Late Form 8621

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 Submission Procedure (DFSP).

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Parag Patel, Esq.

Mr. Patel’s expertise is in all stages of tax controversies including international tax law, foreign bank accounts and disclosures, tax audit defense, and tax appeals. Mr. Patel has counseled over 1000 voluntary tax matters for assets before the US Internal Revenue Service.

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.

Mr. Patel is a New Jersey Super Lawyer by New Jersey Magazine for tax and estate planning. Mr. Patel has also received an AV rating from the Martindale-Hubbell Peer Review Rating System, which is the highest professional rating possible among lawyers. Mr. Patel is the Chairman of the Tax Law Committee of American Bar Association’s GP Solo and Small Firm Division. Mr. Patel is a member of the New Jersey State, New York State, Florida, and American Bar Associations. Mr. Patel has offices in New Jersey, New York, and Florida.

Mr. Patel also serves as Municipal Court Judge for Westfield Township and Edison Township Municipal Courts, with jurisdiction of vehicular violations, temporary restraining orders, criminal and ordinance offenses.

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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 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.

Practice Areas

Foreign Accounts

We have experience with all types of foreign account issues. From the basics to fixing mistakes, we can help.

Foreign Corporations

We have experience with all types of foreign corporation solutions, including Form 5471.

Tax Law Services

We are an experienced tax law firm serving clients nationwide. We assist clients in all types of tax matters including: Tax audit representation, Tax appeals, Offshore Voluntary Disclosure Program (OVDP), Streamline Domestic Offshore Procedure (SDOP), Streamline Foreign Offshore Program (SFOP), Delinquent FBAR Submission Procedure, Tax Settlements, Tax Lien Releases, Tax Penalty Abatement Cases, Installment Agreement Representation, Estate and Gift Tax Planning, Individual Tax Planning and Business Tax Planning.

Estate Planning

We have significant experience with estate planning. An “estate plan,” generally, refers to the means by which your estate is passed on to your loved ones on your death. Estate planning can be accomplished through a variety of methods, including: Revocable Living Trusts, Last Will and Testament / Probate, Lifetime Gifting, Joint Ownership, Beneficiary Designations and Life Estates. We offer a wealth of free information in our website as well as our New Jersey Estate Tax Blog.

Patel Law Offices
60 Walnut Avenue, Suite 202
Clark, New Jersey 07066

Florida Office

Our Florida office is strategically located in Ft. Lauderdale in Broward County, Florida, where we meet clients by appointment only.

We assist many of our clients to re-domicile themselves in Florida, which is one of the lowest tax states in the United States. We help clients with Florida Probate Administration and Florida Estate Settlement. The firm helps with advice regarding Florida probate avoidance, will and trust preparation, and estate planning.