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IRS Sues Taxpayer to Collect on $5M FBAR Penalty

Earlier this month, in United States v. Arvind Ahuja (E.D. Wisc. Dkt. No. 18-cv-01934), the IRS sued a prominent neurosurgeon to reduce to judgment an …

IRS Updates Procedures for Voluntary Disclosures

The IRS issued a memorandum on November 29, 2018 that updates the process for domestic and offshore voluntary disclosures after the 2014 offshore voluntary disclosure …

IRS Includes FATCA in 5 New Compliance Campaigns

Each year the IRS rolls out campaigns to identify the the top compliance issues for the year. For each of these campaigns, the IRS will …

IRS Evaluates Crytocurrency Taxable Events

At a recent conference, the IRS opened up about its cryptocurrency compliance efforts. To combat tax evasion from those engaged in cryto trading, the IRS …

Court Finds Representative of Estate Liable for Deceased’s FBAR Penalties

The Court in United States v. Schoenfeld (M.D. Fla. 3:16-cv-1248-J-34PDB) finds that a deceased taxpayer’s FBAR civil penalty liabilities are collectible from his estate’s beneficiary. Facts Steven …

Tax Court Denies Government Summary Judgement in Foreign Income Case

In Zuhovitzky v. CIR, T.C. Memo 2015-158, the government filed a motion for partial summary judgment on the issue wither the petitioner is subject to …

Late Filed Foreign Earned Income Exclusion

Can the foreign earned income exclusion be elected on a late-filed return? Redfield v. Comm’r, T.C. Memo 2017-71 (T.C. April 26, 2017) answers this question. …

Estate Tax Planning for Non-Residents Owning U.S. Real Estate

IRC § 2101 imposes a tax on the transfer of the taxable estate of a person who was not a U.S. nonresident alien (NRA) at the time …

U.S. Tax on Australian Superannuation Funds

An Australian superannuation fund is a partly compulsory pension program put in place by the Government of Australia. The employer contribution rate has been 9.5% since …

Court Says FBAR Willful Penalty not Limited to $100,000

Breaking from Wadhan and Colliot, the court in Norman v. United States, No. 15-872T (Ct. Cl. 2018) recently held that FBAR willful penalties are not limited to …

Our experience with Kunal Patel has been awesome. He was extremely transparent, always available for advice, very reliable and basically on top of the job. He pointed us in the right direction & cleared our matter very professionally. We would most certainly recommend him,to whoever might need a Tax Attorney.

– S.S., Client

I hired Kunal to assist me with a SDOP application after talking to a few other tax attorneys. He is very professional and methodical in his approach. Also very reasonable with his rates. You will definitely find an ethical lawyer in Kunal and I wish him the best for the future.

– Anonymous, Client

We found Mr. Patel’s services to be professional, speedy, and his rates are very reasonable…We were impressed with his knowledge of the inner workings of the IRS and complicated tax law and found him to be very trustworthy and ethical in a field where many other firms are just out to get your money. I would highly recommend his services and will definitely use his services again.

– L Mascari, Client

Kunal Patel was extremely helpful in solving my tax problems. He is very experienced and professional. Kunal was willing to fight for me to get my issues resolved. I was very happy with the results and highly recommend the Law Office of Kunal Patel!

– F Mann, Client

I hired Kunal for my offshore case. It was fairly complicated and my accountant did not know how to report them. I called a few attorneys and some of them tried to scare me about my situation. I felt comfortable with Kunal. I wanted someone to take their time with my case and do it properly instead of rushing. It was a straightforward process and done very professionally.

– V.R., Client

Kunal helped us with a successful streamlined filing disclosure of foreign assets. He came across as very knowledgeable and answered all our questions…He was efficient and quick in completing the process after we had put together all our documentation. Overall, we had a very good experience working with him. I would strongly recommend him.

– Anonymous, Client

Mr. Patel was very professional and approachable. He listens to clients and does not handle cases just mechanically.
He successfully closed a streamlined offshore procedure.

– Anonymous, Client

Kunal has been really helpful in getting me compliant per the streamline procedures. Kunal was aware of all the nuances related to FATCA and FBAR procedures and gave appropriate recommendation and advice. I would definitely recommend Kunal.

– Sid, Client

I was worried of the potential penalties resulting from failure to report my foreign investments. I approached Kunal to help becoming compliant and he took time to explain about the streamlined domestic procedure. We submitted the application and received the IRS acknowledgement in a few months. Thank you Kunal for your help.

– AB, Client

Mr. Kunal Patel is a very competent tax attorney handling FATCA and overseas taxation. He worked patiently, efficiently and in professional manner in resolving overseas taxes. He is easy to work with. He delivered what he had stated during our consultation. His service charges are quite reasonable. I would recommend him.

– Anonymous, Client

When I first called Kunal I was very worried because I had many years of FBARs and unreported foreign income. Kunal did a good job reassuring me throughout the process and the streamlined application went without any problems.

– J.P., Client