Tax Law Services
We are an experienced tax law firm serving clients nationwide.Foreign Asset Planning
It is not unlawful to have foreign bank accountWills, Trusts and Estate Planning
Our law firm provides highly-personalized, responsive service to estate planning clients as we counsel them at all the critical stages of their lives.Estate Administration
The death of a loved one may be difficult enough to endure without having to worry about the ensuing estate matters.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
Reviews
Janet Knoth ★★★★★
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.
navnit patel ★★★★★
Parag Patel is an excellent tax lawyer. He is a very approachable and answers all questions in detail and in a way that is easy to understand. If you have any offshore tax issues he is the guy you want to talk to. Highly recommended by me and my family.Latest Blog Posts
IRS Transitions from First Time Abatement to Automated Penalty Relief: Strategic Impacts for Tax Advisors
Starting this year, the Internal Revenue Service is transitioning from the manual First Time Abate (FTA) framework to a computerized infrastructure under the newly introduced Automatic Exemption from Penalty (AEP) program. For tax advisors managing tax controversy cases, this systematic shift carries important procedural and strategic implications. While automation promises to reduce administra…
Parag Patel to Present on IRS Foreign Asset Enforcement at the 2026 NATP Taxposium
As international asset transparency reaches an all-time high, the IRS has dramatically escalated its scrutiny of cross-border holdings. For tax professionals, keeping pace with the aggressive enforcement priorities of the Internal Revenue Service (IRS) is a requirement to protect clients from large penalties. To help practitioners navigate this increasingly complex arena, Parag…
The End of the IRS Delinquent FBAR Submission Procedures?: Still Available under IRM 4.26.16.3.11
In federal tax controversy practice, managing the divergence between the IRS’s public-facing administrative declarations (website, FAQs, etc.) and its internal operational guidelines requires careful technical analysis. This distinction has become critical following the action of the Internal Revenue Service on July 1, 2026, when the IRS quietly removed the public webpage of th…
New Court Case on FBAR Penalty Limits
The enforcement of Foreign Bank and Financial Accounts (FBAR) reporting requirements remains one of the highest-stakes areas of tax controversy practice. The IRS continues to aggressively pursue maximum willful penalties against taxpayers with undisclosed foreign accoun
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.