“Seriously Delinquent Tax Debt” Information & Solutions

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 accounts and disclosures, tax audit defense, and tax appeals. Mr. Patel has counseled over 1000 voluntary tax matters for assets before the US Internal Revenue Service.

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 Procedures (SDOP), Streamlined Foreign Offshore Procedures (SFOP), Voluntary Disclosure Practice (VDP), Delinquent International Information Return Submission Procedure (DIIRSP), Delinquent FBAR Submission Procedure (DFSP).

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Parag provided both professional and personal advice in a super timely manner. Would definitely recommend and work with again in the future.

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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.
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Latest Blog Posts

IRS Summons to a Third Party: Duties and Rights


One of the most common evidence-gathering tactics used by the Criminal Investigative Division is the issuance of summonses. The IRS has very broad discretion to use summonses, which are authorized by statute to allow special agents to assess “correctness of a return or liability for tax,” or for the purpose of …

Maryland Retail Store Owner Guilty of Tax Fraud and Tax Evasion


Sunil Chawla (“Chawla”), age 66, of Berlin, Maryland, pleaded guilty this week to tax fraud.  As part of his plea agreement, Chawla will be required to pay $70,000 in restitution.    According to his guilty plea, Chawla owned and operated “India Emporium”, a seasonal retail store near Ocean City, Maryland for …

Specific Steps for Applying to the IRS Streamlined Foreign Offshore Procedures


If you are a US Person and not compliant for not properly reporting foreign accounts, assets, investments, and income to the IRS, you may have learned about Streamlined Procedures. If you live outside the US and are eligible to use the Streamlined Foreign Offshore Procedures, then you must follow the …

US Supreme Court to Rule on FBAR Penalties Case


The debate over FBAR penalties for non-willful failure to disclose all of an individual’s or business’ foreign bank accounts has reached the Supreme Court. The issue is whether the maximum $10,000 Foreign Bank Account Reporting (FBAR) penalty should apply on a per-account basis, or rather than in one unified ann…

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 accounts, investments or income, who can use Form 14654 Certification by U.S. Person Residing in the U.S. to become compliant. This limited tax amnesty solution for U.S. resident taxpayers holding noncompliant foreign accounts has a reduced single year 5% offshore penalty. Our legal team has advised and prepared hundreds of Streamlined cases with the IRS.

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 accounts, investments or income, via Form 14653 Certification by U.S. Person Residing Outside of the U.S. to become compliant. This limited tax amnesty solution for U.S. non-resident taxpayers holding noncompliant foreign accounts has a 0% penalty. Our legal team has advised and prepared hundreds of Streamlined cases with the IRS.

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 account FBAR mistakes for clients around the globe.

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 8938 errors for clients around the globe.

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.




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