What is a seriously delinquent tax debt?IRS CP508C Notice certifies your tax debt as a seriously delinquent federal tax debt revoking passport issuance. There are strategies to avoid the Notice.
ExceptionsThere are numerous exclusions from the definition of a “seriously delinquent tax debt.”
Decertify or ReverseLearn the circumstances where the IRS will decertify or reverse a seriously delinquent tax debt certification and issue a passport.
Frequently Asked QuestionsOur most common questions and answers from our clients with IRS revoked passport problems.
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.
Connect with Parag:
Free Strategy Session
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
Nicholas Visco ★★★★★Extremely knowledgeable and well versed in probate matter. Mr. Patel and his team have been excellent to work with.
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.
Latest Blog Posts
Rare Supreme Court Ruling Favors Taxpayers!
The US Supreme Court rarely hears tax cases, but this week ruled on a case in favor of taxpayers. The case was originally heard because lower courts issued conflicting opinions. This week, the Supreme Court scaled back the federal penalties for failing to file required reports listing foreign bank ac…
Demystifying IRS Agents
The IRS is planning to hire thousands of new agents in the next few years. Some politicians and the media have portrayed the new hires as a harassing threats to taxpayers. In my decades of experience as a tax attorney defending taxpayers on complex tax examinations (e.g., audits), I f…
New Rules: New Jersey Finally Follow Federal S Elections
On December 22, 2022, New Jersey Governor Murphy signed into law a new rule that eliminates the need to make separate New Jersey S elections. The law primarily conforms New Jersey’s laws regarding the making of S elections to federal law. For many years, a corporation could elect to be tre…
Top 5 tax fraud recoveries in 2022
Tax fraud can take many different forms. Below are the top federal tax fraud cases last year. Crypto Seizures: more than $7 billion. In February, 2022, it was announced that IRS Criminal Investigations Cyber Crime Unit led the seizure and recovery of Bitcoin valued at $4.5 billion that had been …
Common Problems Solved
Streamlined Domestic Offshore Procedures (SDOP)
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)
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.
Submission Procedure (DFSP)
8 Penaltie s
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
U.S. owners and investors of certain foreign corporations must
file a Form 547