Internal Revenue Service (IRS) Representatio
We concentrate in the representation of taxpayers before the IRS. We will advise you in face-to-face in person meetings of the best tax strategies before negotiating with the IRS.
We meet you in person and vigorously defend taxpayers under audit. We are often able to minimize audit issues and close audits quickly.
t Defens e
New Jersey Division of Taxatio
We have over 20 years’ experience in aggressively defending taxpayers from the New Jersey Division of Taxatio
IRS Not Collectibl
Unable to pay taxes? We meet you in face-to-face in person meetings to aggressively seek ‘Not Collectibl
e Statu s
Unfiled/Delinquent Tax Return
Unfiled returns can lead to the IRS creating one for you. We creatively eliminate risks of penalties and audit in filing late returns.
Monthly Installment Payment Pla
Payment plans are available in most tax cases. We meet you in face-to-face in person meetings to help you negotiate the best result with an easy payment plan with the IRS.
ns with the IRS
An unknowing spouse can get relief from being jointly and severally liable for unpaid taxes. We can help permanently avoid liability.
e Relie f
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.
Connect with Parag:
Free Strategy Session
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
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.
Rahul Sharma ★★★★★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
What is a Mark-to-Market (MTM) election for a Passive Foreign Investment Company (PFIC)?
Several clients have recently asked us about the Mark-to-Market (MTM) election for a Passive Foreign Investment Company (PFIC). A MTM election for a Passive Foreign Investment Company (PFIC) is an option that allows a taxpayer to treat their investment in a PFIC as if it were a regular marketable secur…
Comments on IRS Form 352
0 to Report Foreign Gifts
The Florida Bar Tax Section recently made some excellent comments in response to the Internal Revenue Service’s request for comments concerning Forms 3520 and 3520-A. The comments were intended to enhance the quality, utility, and clarity of the information to be collected. Some of the selected comments are pasted below. …
REPORTING FOREIGN ASSE
TS & ACTIVITIES: REQUIREMENTS AND CHALLENGES: Complimentary CPE Presentation
Join us for a Complimentary CPE Presentation on Reporting Foreign Asse
Tax Court Rules IRS Cannot Assess or Collect Form 547
Last week the US Tax Court issued its opinion in Farhy v. Commissioner, ruling that the Internal Revenue Service (IRS) could not assess or collect penalties under Internal Revenue Code (Code) Section 6038(b) for a late-filed Form 547
Common Problems Solved
Streamlined Domestic Offshore Procedures (SDOP)
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)
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.
Submission Procedure (DFSP)
8 Penaltie s
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
U.S. owners and investors of certain foreign corporations must
file a Form 547