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Internal Revenue Service (IRS) Representation

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.

Tax Audit Defense

We meet you in person and vigorously defend taxpayers under audit. We are often able to minimize audit issues and close audits quickly.

New Jersey Division of Taxation

We have over 20 years’ experience in aggressively defending taxpayers from the New Jersey Division of Taxation in state tax matters, including sales tax audits, appeals, and collections.

Tax Liens

Protect yourself against tax liens. We meet you in face-to-face in person meetings to aggressively defend against tax liens and can quickly remove tax liens in many cases.

IRS Not Collectible Status

Unable to pay taxes? We meet you in face-to-face in person meetings to aggressively seek ‘Not Collectible’ status to stop collection activity.

Unfiled/Delinquent Tax Returns

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 Plans with the IRS

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.

Innocent Spouse Relief

An unknowing spouse can get relief from being jointly and severally liable for unpaid taxes. We can help permanently avoid liability.

Meet Mr. Patel

Mr. Patel’s expertise is in all stages of tax controversies including international tax law, foreign bank accounts and disclosures, tax audit defense, and tax appeals. Mr. Patel has counseled over 1000 voluntary tax matters for assets before the US Internal Revenue Service.

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 Submission Procedure (DFSP).

Reviews

Nicholas Visco ★★★★★

Extremely knowledgeable and well versed in probate matter. Mr. Patel and his team have been excellent to work with.

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

IRS announces two new intriguing targeted enforcement campaigns


Every so often the Internal Revenue Service announces a new “campaign” to increase tax compliance. A campaign usually means additional IRS focus and resources are allocated to the areas where the IRS is trying to improve compliance. The IRS recently announced the below two campaigns of targeted enforcement of particular interest to our clients and Shar…

President Trump Revamps the IRS through his 2019 Taxpayer First Act


President Trump recently signed the Taxpayer First Act (TFA) of 2019, which for the first time in decades, will dramatically restructure, modernize and (hopefully) improve the Internal Revenue Service. There are several ways the new taxpayer-friendly law will reform the IRS and improve the IRS’ generally bad reputation. The TFA has many welcome developments regarding Shar…

The IRS Large Business and International division (LB&I) has announced a new Post OVDP Compliance enforcement campaign


The new Post OVDP Compliance enforcement campaign was recently identified through LB&I data analysis and suggestions from IRS employees. IRS employees likely saw that many taxpayers were not properly reporting offshore bank accounts, as a result, they suggested the campaign. The IRS Post OVDP Compliance enforcement campaign goal is to improve return selection, identify issues Shar…

New IRS Enforcement Letters Warn of Cryptocurrency Non-Compliance


Last week, the Internal Revenue Service began sending letters to taxpayers with virtual currency transactions that potentially failed to report income and pay the resulting tax from virtual currency transactions or did not report their transactions properly. “Taxpayers should take these letters very seriously by reviewing their tax filings and when appropriate, amend past returns Shar…

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 accounts, investments or income, who can use Form 14654 Certification by U.S. Person Residing in the U.S. to become compliant. This limited tax amnesty solution for U.S. resident taxpayers holding noncompliant foreign accounts has a reduced single year 5% offshore penalty. Our legal team has advised and prepared hundreds of Streamlined cases with the IRS.

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 accounts, investments or income, via Form 14653 Certification by U.S. Person Residing Outside of the U.S. to become compliant. This limited tax amnesty solution for U.S. non-resident taxpayers holding noncompliant foreign accounts has a 0% penalty. Our legal team has advised and prepared hundreds of Streamlined cases with the IRS.

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 is the FinCEN Form 114, which is commonly misunderstood. A delinquent or late FBAR is subject to very high penalties. The DFSP is one of the four methods for taxpayers with unreported offshore accounts to become compliant. Taxpayers who have failed to an FBAR can use the DFSP to cure the non-compliance. While there is no DFSP penalty the DFSP has complex rigid eligibility requirements. Our legal team mitigates foreign account FBAR mistakes for clients around the globe.

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 8938 errors for clients around the globe.

Form 5471 Penalties

U.S. owners and investors of certain foreign corporations must file a Form 5471, otherwise there are very high Form 5471 Penalties. Form 5471 is a complex form with many common mistakes. because of the expansive disclosure of corporation's assets, liabilities and equity. Our legal team can help you fix late or unfiled Form 5471 errors.