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.
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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
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.
Rahul Sharma ★★★★★Parag provided both professional and personal advice in a super timely manner. Would definitely recommend and work with again in the future.
Latest Blog Posts
U.S. Citizens who have a financial interest in or signature authority over foreign bank account
What to do After Receiving Notice CP 15 or CP 215 for Failure to Timely File Form 352
When receiving a penalty for failure to timely file Form 352
Penalties for Not Filing Form 352
The IRS requires a U.S. person receiving a gift from a foreign individual, corporation, partnership, or estate to report by filing Part IV Form 352
Foreign Gifts and the Uncommon Form 352
0: A Trap for the Unwary
When a U.S. person receives a gift from a foreign individual, corporation, partnership, or estate which is treated as a gift or bequest and excluded from gross income, the recipient may be required to file Part IV of Form 352
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
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
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