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
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Extremely knowledgeable and well versed in probate matter. Mr. Patel and his team have been excellent to work with.Latest Blog Posts
Expect new aggressive IRS targeted enforcement next year.
For years, the government has known about the widening tax gap, which reports uncollected taxes among US taxpayers. However, typically, the government does not do much to address the increasing loss of tax revenue. It appears that is about to change. President Biden is about to announce a major new inc…
The big question on a tax increases is not “if” but “when”
We expect taxes to increase. The big question however is when the increase(s) will take effect. Although it is politically unpopular and unfair to change tax laws after people rely on them in making transactions through the year, legally (and constitutionally), a tax increase can be imposed retroactively (i.e., starting e…
The Dreaded IRS Letter 6185: “We received information that you have a foreign account ”
Many of our clients have recently received IRS Letter 6185, which begins with “Why we’re writing to you: We received information that you held an interest in one or more foreign financial accounts, foreign entities, or foreign financial assets.” This letter is an IRS “soft letter” (i.e., a warning letter) to U…
Increased IRS Enforcement Expected Against High-Income Taxpayers
The US Treasury Inspector General for Tax Administration (TIGTA), in two recent reports, said that the IRS collected more tax revenue in 2019 than in any other previous year but, at the same time, overlooked high-income delinquent taxpayers and so missed out on billions more. TIGTA is a government watchdog agency that…
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.