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
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.
Nicholas Visco ★★★★★
Extremely knowledgeable and well versed in probate matter. Mr. Patel and his team have been excellent to work with.Latest Blog Posts
New Mandatory E-filing Form 8300 for Reporting of Large Cash Currency Transactions
The IRS announced yesterday that certain businesses that receive payments of over $10,000 in cash must file Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business, electronically starting in 2024, the IRS said in a news release (IR-2023-157). This new requirement applies to businesses that are required to …
IRS Uses New Funding to Target US Persons with Malta Accounts
The US Treasury and US Internal Revenue Service are to leverage more resources to detect Americans using Malta personal pension accounts to claim tax exempt income, it said in a statement last week. The additional resources to investigate the Malta schemes will come from the Inflation Reduction Act, the Treasury sai…
NJ Contractor Charged with Criminal Tax Evasion for Unreported Checks
A Union County NJ contractor was arrested last week for tax evasion for not reporting cashed check income. Joel Konopka, 45, of Elizabeth, New Jersey, is charged by indictment with four counts of corporate tax evasion, two counts of filing false corporate tax returns, and two counts of failing to file corp…
Beware the New 2023 Form 1099-K
Beginning in 2023, third-party payment networks must file Form 1099-K with the IRS and provide a copy to the taxpayer when the gross payment amount exceeds $600. However, not all payments from third parties are taxable. Taxpayers can take steps to prevent non-taxable items from being reported. They also can remedy a third-party payment re…
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
Malta Pension Plan Problems
Malta Pension Plans have been criminally and civilly investigated by the IRS and are on the IRS "dirty dozen" list. Recently in late 2021, the United States and Malta entered an agreement regarding Malta pension rollovers. We have assisted dozens of taxpayers with compliance and solutions with Malta Pension Plan problems.