Resolving IRS disputes through audit reconsideration

- By : P. Patel

An audit reconsideration is defined by the Internal Revenue Manual (IRM) as: the process the IRS uses to reevaluate the results of a prior audit where additional tax was assessed and remains unpaid, or a tax credit was reversed. If the

Taxation of Employment-related Discrimination Claims

- By : P. Patel

Proceeds from a settlement involving an employment-related discrimination case may be taxable to the employee under some circumstances and not taxable in others.   Non-taxable settlement amounts: Medical expenses associated with medical distress; Emotional distress, pain or suffering resulting from

Article Discusses Termination of Offshore Voluntary Disclosure Program (OVDP) and the Streamlined Filing Compliance Procedures (SFCP)

- By : P. Patel

The Internal Revenue Service (IRS) currently offers non-compliant US taxpayers several different relief programs in which to report foreign assets and/or income and become compliant with US rules related to the disclosure of foreign assets. One option is the Offshore

Income Taxation of FMLA Claims

- By : P. Patel

The Family Medical Leave Act requires employers with 50 or more employees to grant 12 weeks of unpaid leave to an employee in the event of a birth, adoption or serious health condition — whether it’s the employee or someone

Happy Birthday Streamlined Filing Compliance Procedure!

- By : P. Patel

The Streamlined Filing Compliance Procedure (SFCP) was “born” two years old.  Two years ago the IRS publicly announced the SFCP, which has been used by many non-compliant US taxpayers with the disclosure of foreign assets. SFCP has two sub-programs: one

How to Respond to an IRS CP3219N Notice of Deficiency (90-day letter)

- By : P. Patel

Under Sec. 6212(a) the IRS can issue a statutory notice of deficiency, also known as a 90-day letter, when it determines a deficiency in an income or estate and gift tax liability. A 90-day letter is a formal legal notice,

New Trust Law Enacted in New Jersey

- By : P. Patel

On January 19, 2016, the New Jersey Uniform Trust Code (NJUTC) was enacted into law.  The new law will take effect on July 17, 2016.  The new law, based in part on model legislation prepared by the Uniform Law Commission,

US Entities with foreign assets have more information reporting

- By : P. Patel

The US Treasury has issued long-awaited regulations specifying the domestic taxpayers who have to disclose substantial foreign financial assets to the Internal Revenue Service (IRS) every year. The new rules, effective immediately, are linked to the Foreign Account Tax Compliance

The Tax Heat is On

- By : P. Patel

At the recent American Bar Association meeting held on January 29, 2016, the acting Attorney General for the tax division disclosed that the IRS and US Department of Justice are now focusing bank investigations in Belize, the British Virgin Islands,

Becoming Un-American: Record number of US citizens renounce their US citizenship

- By : P. Patel

A record 4,279 people renounced their U.S. citizenship or long-term residency in 2015, according to new data released by the Treasury Department. Last year was the third year in a row that renunciations have increased to record levels and the

New IRS Forms Informs Beneficiaries of Asset Basis Values

- By : P. Patel

Instructions to IRS Form 8971 for reporting the asset basis of estates have now been finalized. Form 8971, Information Regarding Beneficiaries Acquiring Property From a Decedent, tells estate executors and others required to file a Form 706 how to report

US real property now more attractive for certain foreign investors

- By : P. Patel

On 18 December President Obama enacted the Protecting Americans from Tax Hikes (PATH) Act of 2015, extending several temporary tax relief provisions either permanently or for two or five years. PATH also amends the Foreign Investment in Real Property Tax

New law complicates US Passport issuance

- By : P. Patel

Pending legislation, H.R. 22 called Developing a Reliable and Innovative Vision for the Economy (DRIVE) Act, is likely to be passed law next month. This law will have major implications for those with federal tax debts wishing to apply for

What FATCA Means to You and Your Investments

- By : P. Patel

You may have recently received a letter from your financial institution or investment firm asking for some of your personal details.  Typically the letter requests many personal, tax and residency details, such as your country of birth, the country in

Answers to Common Questions for IRS CP3219N Notice of Deficiency (90-day letter)

- By : P. Patel

What you need to do If you want to challenge the deficiency determination, file a petition with the Tax Court. File your tax return immediately (no later than 90 days from the date of the CP3219N), or accept our proposed