Search Results for: penalties
The IRS Large Business and International division (LB&I) has announced a new Post OVDP Compliance enforcement campaign
…accounts, or assets. However, taxpayers must comply with income tax and information reporting requirements associated with these foreign activities, otherwise they are subject to penalties and possible criminal prosecution. OVDP…
The IRS’s 2022 Dirty Dozen tax scams
…exposing themselves to civil fraud penalties and criminal charges that could result from failure to report transactions involving digital assets. High-income individuals who don’t file tax returns: The IRS continues to…
IRS Enforcement Campaign Targets High-Income Non-Filers
…2017 through 2021. The IRS expects this initiative to yield significant recovery of unpaid taxes, along with associated penalties and interest. This effort aligns with the IRS’ broader focus on…
New Taxpayer Advocate Service Report Discusses Optouts out of the OVDI/OVDP
…result in a reduction of penalties that may otherwise be assessed, the taxpayer needs to carefully weigh the numerous consequences before doing so. Responsible tax professionals should discuss the consequences…
Upcoming live video webinar: U.S.-India Tax Planning: Reporting Issues, Traps to Avoid, Tax Treaties, FTC, FACTA/FBAR Reporting, Passive Income
…will need to understand the domicile rules to avoid costly taxes and penalties. Other areas of concern in U.S.-India tax planning include treating passive income and tax considerations for retirement…
Global Enforcement of FATCA: Something to Worry About
…harsh criminal (in addition to civil) penalties. The risks may outweigh the benefits. Patel Law Offices is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and…
IRS examines jewelry, precious stones and metals businesses for compliance
…They review books and records, including bank statements, to make this determination. Failure to file the 8300 can result in fines, penalties, and, in extreme cases, criminal prosecutions. Historically, the…
US Reporting of Foreign Retirement Accounts
…specified retirement age, disability, or death, or penalties must apply to withdrawals made before such conditions are met. However, an exception is provided for early withdrawals for hardship or education…
NJCPA Seminar “The Corporate Transparency Act: What You Need To Know”
…are the penalties for noncompliance? What steps should one take to comply? What’s next? Experienced tax attorney Parag Patel has handled hundreds of complex tax matters for clients. The New…
Beware of U.S. tax consequences to a foreign trust with a U.S. beneficiary
…Statement includes the distributable net income for the year, the years to which an accumulation distribution is attributed, and the amounts allocable to each year. Extremely high penalties may apply…
BUSINESS SUCCESSION LEGAL PLANNING
…independent expert. The valuation process has been around since 1959 and has been well-treated by the courts. It carries stiff penalties for over-under valuation, hence strict adherence is mandatory. Buy-Sell…
COURT AUTHORIZES SERVICE OF JOHN DOE SUMMONS SEEKING THE IDENTITIES OF U.S. TAXPAYERS WITH OFFSHORE ACCOUNTS AT CIBC FIRSTCARIBBEAN INTERNATIONAL BANK
…HSBC India accountholders seriously consider entering the IRS OVDP program for protection against civil (and criminal) penalties. Patel Law Offices is a law firm dedicated to helping clients resolve complicated…
A solution in a tough tax season: the IRS Streamlined Offshore Procedures
…facts will be considered incomplete and will not qualify for streamlined penalty relief.” Importantly, taxpayers should always bear in mind that they sign their non-willful conduct certification narrative under penalties…
FBAR Deadline is June 28, 2013
…the postmark to establish timely filing. Significant penalties apply to taxpayers who fail to timely fail their FBAR. This will be the last year individuals may file paper FBARs. Beginning…
The Teeth of the Foreign Account Tax Compliance Act (FATCA)
…disclosure submission, there could be harsh criminal (in addition to civil) penalties. The risks may outweigh the benefits. Patel Law Offices is a law firm dedicated to helping clients resolve…
Solution: Streamlined Domestic Offshore Procedures
…considered incomplete and will not qualify for streamlined penalty relief.” Importantly, taxpayers should always bear in mind that they sign their non-willful conduct certification narrative under penalties of perjury. Evidence…
Denied access to or withdrew from the IRS Offshore Voluntary Disclosure Program (OVDP)?
…Accounts (FBARs). Submissions under Option #2 may result in the IRS proposing penalties and/or conducting an audit. Option #3 allows taxpayers who believe they are already fully compliant to submit…
REPORTING FOREIGN ASSETS & ACTIVITIES: REQUIREMENTS AND CHALLENGES: Complimentary CPE Presentation
…FBAR penalties Summary of most common international tax reporting forms RSVP: https://www.wgcpas.com/reporting-foreign-assets-activities-requirements-and-challenges/ CPE: 1.5 NJ credits WHEN: Monday, April 24th, 2023 Networking & Snacks: 6:00-6:30 PM CPE Seminar: 6:30-8:00 PM…
Parag Patel Esq. Speaks at NJCPA Seminar on”Employee Retention Credit Audit Issues: Surviving IRS Scrutiny”
…qualify” and noted that these mills usually charge upfront or contingent fees for their services. Penalties for improperly claiming the ERC are very high and could include a 20 percent…
Parag Patel Esq. Speaks at NJCPA Seminar on”The Corporate Transparency Act: What You Need To Know”
…the penalties for noncompliance? What steps should one take to comply? What’s next? Experienced tax attorney Parag Patel has handled hundreds of complex tax matters for clients. The New Jersey…
Run to the Door: IRS Terminates Offshore Voluntary Disclosure Program (OVDP) effective September 28, 2018
…comply voluntarily. All told, those taxpayers paid a total of $11.1 billion in back taxes, interest and penalties. The planned end of the current OVDP also reflects advances in third-party…
Is HSBC the next UBS nightmare?
…concerned about disclosure of the account to the government, which could result in criminal prosecution and significant civil penalties. Our law firm advises and aggressively defends taxpayers in voluntary disclosures…
NJ Division of Taxation Announces Conferences and Appeals Branch Initiative
…consideration for an abatement of penalties, other than the 5% amnesty penalty. These requests must be in writing and must indicate reasonable cause for failure to file any return or…
New Warnings in the IRS’ Streamlined Filing Compliance Procedures
…and file all required information was due to non-willful conduct. In either version of the form, the taxpayer is certifying, under penalties of perjury, that: “My failure to report all…
New Leak of Offshore Accountholders Highlights the Need to Clean Up
…total assets exceed generally $100,000 (there are many other applicable limits) on another Form 8938. The Form 8938 is filed with the normal income tax return filing. Beware: Punitive penalties…
Common Issues for US-India Tax Reporting
…amnesty programs, under which a previously non-compliant individual can become compliant and avoid potentially very high penalties or criminal prosecution. However these amnesty programs generally require the taxpayer to come…
US Department of Justice Encourages Swiss banks to Disclose Information
…eligible for a non-prosecution agreement, Category 2 banks must meet several requirements, which include agreeing to pay penalties based on the amount held in undeclared U.S. accounts, fully disclosing their…
IRS’ Takes Legal Action Against Offshore HSBC Indian Accounts
…back taxes and interest, as well as accuracy-related penalties. Under the regular FBAR rules, a taxpayer could pay up to 50% of the highest amount in each account for each…
With No More Amnesty Program: Explore the IRS’s Traditional Voluntary Disclosure program
…Program, now is the time for you to come forward and learn about other options the IRS provides in regards to voluntary disclosure in order to limit potential civil penalties…
IRS Most Common Tax Notices and What They Mean
…recommend the steps needed in order to respond to the notice and determine if any additional taxes, interest and penalties are due. You should request that your tax advisor carbon…