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 Procedures (SDOP), Streamlined Foreign Offshore Procedures (SFOP), Voluntary Disclosure Practice (VDP), Delinquent International Information Return Submission Procedure (DIIRSP), Delinquent FBAR
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.
Ajit Desai ★★★★★
" We highly recommend Patel Law Services. Patel and his team were attentive, knowledgeable and very professional in helping us navigate a complicated legal landscape. We are glad a quality law firm like Patel law services operates in central jersey , NJ area."Latest Blog Posts
Do Inherited Foreign Asset s Receive a Step-up in Cost Basis for U.S. Tax Purposes?
A common question asked by clients when receiving an inheritance from outside the United States is about the U.S. cost basis and receiving a step-up in basis on foreign asse
Forms 5471, 5472, 3520 Partial Penalty Relief Still Available for 2019 and 2020 Returns
IRS Notice 2022-36 provided relief for certain taxpayers from certain failure to file penalties and certain international information return penalties with respect to tax returns for tax years 2019 and 2020 that are filed on or before September 30, 2022. Post Sep 30, 2022 Options Taxpayers who missed the September 30 filing dea…
Parag Patel Esq. speaks at New Jersey Society of Certified Public Accountants (NJCPA) Annual Tax Seminar: “A New Foreign Frontier: Foreign Income & Asset Reporting Update”.
Parag Patel Esq. will be a featured speaker at a New Jersey Society of Certified Public Accountants (NJCPA) Seminar entitled “ A New Foreign Frontier: Foreign Income & Asset Reporting Update ” on November 18, 2022. Seminar Summary: The IRS is aggressively targeting taxpayers with unreported foreign accoun
IRS Announces Increased 2023 Gift Tax Annual Exclusion, Gift, and Estate Tax Exemptions
The Internal Revenue Service recently released the annual inflation adjustments for tax year 2023, which include welcome increases for wealth transfer tax planning. The gift tax annual exclusion will increase for the second year in a row, rising to $17,000 per recipient in 2023 (up from $16,000 in 2022). This mean…
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
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 547