FBAR Basics
Everything you need to know about foreign accounThe Top 12 FBAR Reporting Mistakes to Avoid
There are many common errors in foreign accounMeet 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
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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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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
The Trust Fund Recovery Penalty in Focus: United States v. Flaim and the Unwavering Standard of “Willfulness”
The Trust Fund Recovery Penalty (TFRP), authorized under Internal Revenue Code (I.R.C.) § 6672, remains one of the IRS’s most potent collection tools, allowing the IRS to hold individuals personally liable for an employer’s failure to remit withheld income and employment taxes. A decision this month from the United States District Cour…
₿ Reporting Digital Assets: Understanding the Basic Income Tax Rules for Cryptocurrency
The landscape of digital asset taxation continues to evolve, but the core principle established by the Internal Revenue Service (IRS) remains firm: cryptocurrency is treated as property, not currency, for Federal income tax purposes. This foundational ruling, initially laid out in IRS Notice 2014-21, dictates that nearly every transaction involving a d…
The End of an Era: The IRS Eliminates the Acknowledgement of the Facts IDR
In a long-awaited change that will bring relief to tax professionals, the Internal Revenue Service (IRS) has confirmed the elimination of the Acknowledgement of the Facts (AOF) Information Document Request (IDR). This procedural shift, detailed in guidance such as LBI-04-0725-0008, marks the end of a process that, for over a decade, has …
IRS Appeals Enhances Post Appeals Mediation (PAM) for Greater Taxpayer Leverage
The Internal Revenue Service (IRS) Independent Office of Appeals has initiated a significant two-year pilot program for Post Appeals Mediation (PAM), signaling a commitment to Alternative Dispute Resolution (ADR) and offering tax professionals new strategic opportunity in unsettled cases. Announced on October 1, 2025, in IR-2025-100 these changes fundamentally reshape the post-Appeals landscape.…
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.