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.Exceptions
There are numerous exclusions from the definition of a “seriously delinquent tax debt.”Decertify or Reverse
Learn the circumstances where the IRS will decertify or reverse a seriously delinquent tax debt certification and issue a passport.Frequently Asked Questions
Our 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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About Us
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
Reviews
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.
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
IRS announces two new intriguing targeted enforcement campaigns
Every so often the Internal Revenue Service announces a new “campaign” to increase tax compliance. A campaign usually means additional IRS focus and resources are allocated to the areas where the IRS is trying to improve compliance. The IRS recently announced the below two campaigns of targeted enforcement of particular interest to our clients and Shar…
President Trump Revamps the IRS through his 2019 Taxpayer First Act
President Trump recently signed the Taxpayer First Act (TFA) of 2019, which for the first time in decades, will dramatically restructure, modernize and (hopefully) improve the Internal Revenue Service. There are several ways the new taxpayer-friendly law will reform the IRS and improve the IRS’ generally bad reputation. The TFA has many welcome developments regarding Shar…
The IRS Large Business and International division (LB&I) has announced a new Post OVDP Compliance enforcement campaign
The new Post OVDP Compliance enforcement campaign was recently identified through LB&I data analysis and suggestions from IRS employees. IRS employees likely saw that many taxpayers were not properly reporting offshore bank accounts, as a result, they suggested the campaign. The IRS Post OVDP Compliance enforcement campaign goal is to improve return selection, identify issues Shar…
New IRS Enforcement Letters Warn of Cryptocurrency Non-Compliance
Last week, the Internal Revenue Service began sending letters to taxpayers with virtual currency transactions that potentially failed to report income and pay the resulting tax from virtual currency transactions or did not report their transactions properly. “Taxpayers should take these letters very seriously by reviewing their tax filings and when appropriate, amend past returns Shar…
Common Problems Solved
Streamlined Domestic Offshore Procedures (SDOP)
The Streamlined
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)
The Streamlined
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.
Delinquent FBAR Submission Procedure (DFSP)
The FBAR is the FinCEN
Form 114, which is commonly misunderstood.
A delinquent or late FBAR is subject to very
high
penalties. The DFSP is one of the four methods for taxpayers with unreported
offshore accounts to become compliant. Taxpayers who have failed to an FBAR can
use the DFSP to
cure the non-compliance. While there is no DFSP penalty the DFSP has complex rigid
eligibility requirements. Our legal team mitigates foreign accoun
Form 8938 Penalties
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
Form 5471 Penalties
U.S. owners and investors of certain foreign corporations must file a Form 5471, otherwise there are very high Form 5471 Penalties. Form 5471 is a complex form with many common mistakes. because of the expansive disclosure of corporation's assets, liabilities and equity. Our legal team can help you fix late or unfiled Form 5471 errors.