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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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."
Nicholas Visco ★★★★★
Extremely knowledgeable and well versed in probate matter. Mr. Patel and his team have been excellent to work with.Latest Blog Posts
The IRS Starts Using AI in Tax Functions
Earlier this month, the Internal Revenue Service (IRS) has reportedly initiated a deployment of Salesforce’s AI platform, Agentforce, across key controversy and compliance divisions—including the Office of Chief Counsel, the Office of Appeals, and the Taxpayer Advocate Service (TAS). The deployment presents a material change to IRS administrative tax procedure. Context: Technolog…
The $90 Million Red Flag: Concealment, Trust Funds, and the Peril of Undocumented Labor in the Padilla Indictment
The federal indictment of Lorena Padilla of Villa Park, California, and her co-defendants is not merely a case of employment tax delinquency. It is a definitive example of how the government targets sophisticated schemes involving the willful evasion of tax obligations, resulting in an alleged $90 million tax loss. This case holds cri…
Parag Patel, Esq. Presents “Latest Federal Tax Controversy Update” for NJCPA Membership+
Parag P. Patel, Esq. delivered a presentation today via a live webcast titled “Latest Federal Tax Controversy Update.” The session reviewed a discussion of the One Big Beautiful Bill Act (OBBB Act). (NJCPA). Additional highlights included IRS enforcement updates and new reporting and compliance requirements for accountants and their clients. (NJCPA) This pres…
Parag Patel, Esq. Presents at New Jersey Society of Certified Public Accountants — “One Big Beautiful Bill”
Parag Patel delivers a presentation for the NJCPA Membership in Union County on Tuesday, November 18, 2025, titled “One Big Beautiful Bill”. The session focuses on the implications of the “One Big Beautiful Bill” legislation as it intersects with tax planning, compliance, and controversy risk. What Attendees Learned Parag addresses critical topi…
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.