IRS Has New Procedures for Scrutinizing Quiet Disclosures

- By : P. Patel

A Quiet Disclosure occurs when a person intentionally files tax returns (either amended or original returns, FBARs, and/or other International Informational Returns) outside of one of the IRS’ formal voluntary disclosure In other words, the individual submits the returns and

Significant FBAR Penalties Upheld by Court

- By : P. Patel

Taxpayers have lost and the US Internal Revenue Service has scored a victory over the taxpayer in Kimble v USA, a court case concerning the reporting of foreign bank accounts. The taxpayer, Alice Kimble, held Swiss accounts at both HSBC and UBS in

Analysis: IRS New Disclosure Program

- By : P. Patel

On November 29, 2018, the IRS released a memorandum that addressed the process for all voluntary disclosures following the end of the Offshore Voluntary Disclosure Program (“OVDP”) on September 28, 2018. The new voluntary disclosure procedure provides uniformity to offshore

IRS Updated Voluntary Disclosure Practice is a Game-Changer

- By : P. Patel

Last week the IRS released a memorandum with new procedures for  an “Updated Voluntary Disclosure Practice” impacting all voluntary disclosures. The new updated voluntary disclosure practice (VDP) is a game-changer for offshore voluntary disclosures for US persons with unreported foreign assets. The

New Jersey Tax Amnesty program

- By : P. Patel

Today the New Jersey Division of Taxation announced the launch of their Tax Amnesty program. The program is intended to provide individuals and businesses with the opportunity to pay back taxes or file past returns with no penalties and reduced

The IRS can revoke your passport

- By : P. Patel

If you do not pay your taxes, the IRS may revoke your passport. As the National Taxpayer Advocate (NTA) Nina E. Olson has recently pointed out in her blog, when a taxpayer is notified of such pending revocation, that the taxpayer, nor

New Jersey Enacts Tax Amnesty Bill

- By : P. Patel

Enacted legislation requires the New Jersey Division of Taxation to establish a 90-day state tax amnesty period that ends no later than January 15, 2019. The Legislature had previously passed a bill requiring a six-month amnesty period that had to

The TCJA and the Future of American Taxpayers

- By : P. Patel

Our article on the new tax law was published today by the American Bar Association below… https://www.americanbar.org/groups/gpsolo/publications/gpsolo_ereport/2018/june-2018/tcja-future-american-taxpayers.html The TCJA and the Future of American Taxpayers Vol. 7, No. 11 Parag Patel and Anannya Tripathy Parag Patel, Esq., is a tax attorney in

2018 ABA COMMENTS ON THE OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND THE STREAMLINED PROGRAMS

- By : P. Patel

We are members of the American Bar Association Section of Taxation, which on May 2, 2018 submitted comments to the IRS on the IRS Offshore Voluntary Disclosure Program (“OVDP”), the Streamlined Domestic Offshore Program (“SDOP”), and the Streamlined Foreign Offshore Program (“SFOP”).

IRS reminds those with foreign assets about U.S. tax obligations

- By : P. Patel

The IRS again reminded taxpayers yesterday about their reporting obligations for foreign assets and income. The reminder again represents the IRS’ targeted enforcement of tax laws for reporting obligations for foreign assets and income. Taxpayers should take notice and become compliant. The

Run to the Door: IRS Terminates Offshore Voluntary Disclosure Program (OVDP) effective September 28, 2018

- By : P. Patel

IRS Issue Number:    IR-2018-52 IRS to end offshore voluntary disclosure program; Taxpayers with undisclosed foreign assets urged to come forward now WASHINGTON – The Internal Revenue Service today announced it will begin to ramp down the 2014 Offshore Voluntary Disclosure Program

FBAR statute of limitations court case ruling

- By : P. Patel

In its first decision of 2018, the US Tax Court considered whether the six-year statute of limitations in Code Section 6501(e)(1)(A)(ii) applied to a taxpayer who failed to file Foreign Bank Account Reporting, or FBAR forms from 2006 through 2008.

The 65-Day Rule: What Every Trustee Should Know about Taxes

- By : P. Patel

Happy New Year!  With the close of the calendar year behind us, tax season is just beginning for individuals and many entities.  If you are serving as the trustee of a complex trust, however, it’s not too late to take

Some FBAR Deadlines Extended

- By : P. Patel

Last week the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) again extended the deadline for certain financial professionals to file foreign bank accounting reporting forms known as FBARs. In FinCEN Notice 2017-1, FinCEN announced a further extension of time for certain

IRS Advisory: Prepaid Real Property Taxes May Be Deductible in 2017 if Assessed and Paid in 2017

- By : P. Patel

The Internal Revenue Service advised tax professionals  today that pre-paying 2018 state and local real property taxes in 2017 may be tax deductible under certain circumstances. The new tax law signed last week in Washington prohibited the deduction of prepaid

New 2018 Tax Law’s Business Tax Changes

- By : P. Patel

President Donald Trump signed the new 2018 tax law “Tax Cuts & Jobs Act” (TCJA) last week.  The new TCJA law is a sweeping overhaul of the tax code. Generally, the provisions in the TCJA take effect on January 1,

New 2018 Tax Law’s Individual Tax Changes: New Tax Brackets, Credits and Deductions

- By : P. Patel

President Donald Trump signed the new 2018 tax law “Tax Cuts & Jobs Act” (TCJA) last week.  The new TCJA law is a sweeping overhaul of the tax code. Generally, the provisions in the TCJA take effect on January 1,

4 tax strategies before Jan. 1 to lower your tax bill under the new tax law

- By : P. Patel

  Give more to charity in 2017. Have you been meaning to donate? If so, get it done by year’s end. It helps reduce your income this year when tax rates are higher. Plus, you might not end up itemizing

IRS Announces New international campaigns

- By : P. Patel

On November 3, 2017, the IRS announced an additional 11 compliance campaigns as areas of focus for the Large Business & International Division (“Announcement”). The 11 newly identified campaigns focus primarily on international issues, with seven international campaigns and four

IRS Notice CP 503: IRS Second Notice of Balance Due: What to Do

- By : P. Patel

An IRS CP 503 notice is a letter that the IRS sends out to individuals as a reminder and a means to collect on a tax debt balance. This letter is a final notice and follows previous attempts to receive

Taxpayer Tips: Best Practices for U. S. Tax Court

- By : P. Patel

Taxpayers contesting IRS assessments of additional taxes, penalties and interest have a number of different options to contest and appeal those assessments. One of those options includes bringing a case to the United States Tax Court (Tax Court). Here are some Tax

Beware IRS Forms W-8

- By : P. Patel

Over the past few months we received many inquiries from clients and parties asked by companies to complete IRS Form W-8. Beware Form W-8 is generally filled out by foreign non-US entities or persons (citizens and corporations) in order to