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 TaxatioIRS Not Collectible Status
Unable to pay taxes? We meet you in face-to-face in person meetings to aggressively seek ‘Not CollectiblUnfiled/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 Plan s 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 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
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
Late Disclosure of Foreign Gift for Wedding Results in Penalty
The ongoing litigation over the Internal Revenue Service’s administrative authority to assess international information-return penalties has entered a new phase. For the past few years, the tax community has closely monitored structural challenges to the Service’s penalty powers, particularly following the high-profile litigation concerning Section 6038. However, a major decision issued …
Kwong: Preserving Client Claims for COVID-Era Penalty and Interest Refunds
The U.S. Court of Federal Claims recently issued a landmark ruling in Kwong v. United States, 179 Fed. Cl. 382 (2025), that profoundly alters the landscape of Internal Revenue Service (IRS) compliance enforcement for the pandemic era. For tax practitioners, this decision exposes a massive vulnerability in how the IRS assessed failure-to-file penalties, failure-…
Internal Revenue Service’s Clarification on Reasonable Cause for Form 5472 Penalties
In an era of intensified international tax penalty enforcement, advising foreign-owned domestic corporations requires absolute precision. Among the most punitive enforcement mechanisms in the Internal Revenue Code is the Form 5472 filing requirement under Section 6038A and Section 6038C. A single unfiled or incomplete form carries an automatic $25,000 initial penalty, making …
Defending the Cross-Border Client: Join Parag at the NJSEA Annual Conference This June
The boundary between civil tax non-compliance and criminal tax exposure has never been more porous. As the Internal Revenue Service aggressively expands its enforcement footprint utilizing advanced data analytics, practitioners must be prepared to handle both complex international compliance structures and high-stakes criminal investigations. For tax professionals, staying ahead of these s…
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.