Kunal Patel, EA, JD helps individuals in the U.S. and abroad with cross-border tax issues. With over a decade in private practice, he also draws from his prior background at a Big 4 accounting firm and as a IRS tax examiner.
Who we help
U.S. residents with foreign accounts or income. U.S. tax return and FBAR reporting non-compliance with regards to foreign bank accounts, investments, pensions, or property. We resolve these through the Streamlined Domestic Offshore Procedures, the delinquent FBAR and information return procedures, or the IRS Voluntary Disclosure Practice.
Americans living abroad. U.S. citizens and green card holders overseas who are behind on U.S. returns or FBARs. We use the Streamlined Foreign Offshore Procedures, with foreign tax credits and treaty positions to limit double taxation.
New U.S. residents and foreign owners. Missed filings such as FBARs, Form 8938, Form 3520 for foreign gifts or inheritances, Form 8621 for foreign funds, or Form 5471.
International penalty notices. Already penalized for a late FBAR or Form 3520, 5471, or 5472? We pursue abatement and appeals.
The right path depends on your facts, especially whether the IRS would view the failure as willful. Choosing the wrong one can cost more than the original mistake.
Why clients choose us
- An insider’s view of the IRS. Years at the IRS conducting examinations. We prepare every submission knowing it can be detail-reviewed.
- Big Four international experience. Cross-border work for expatriates and foreign nationals at KPMG.
- Hundreds of offshore matters since 2016, from single accounts to multi-million-dollar portfolios, foreign entities, and PFICs.
- Clients across the U.S. and around the world.
For CPAs and attorneys
When a client’s return turns up an unreported foreign account or a missed information return, we are happy to help. We handle the disclosure strategy and IRS communication; you keep the client relationship.