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IRS to End Offshore Voluntary Disclosure Program

The IRS announced recently that it is ending the OVDP program which has been in existence since 2009. Here are more details from the announcement. …

IRC 6038 & Reasonable Cause for Form 5471 Penalties

Dewees v. United States, 16-cv-01579 (D.C. 2017) is a difficult case. The IRS appears to have been unusually tough on this taxpayer. Dewees is a U.S. citizen …

Foreign Accounts Compliance and Statute of Limitations

IRC § 6038D, enacted on Mar. 18, 2010, and effective for taxable years beginning after the date of enactment, imposes reporting requirements with respect to …

CFCs and Subpart F Income

While a U.S. corporation is subject to tax on its earnings and then its shareholders on their dividends, the U.S. has no taxing jurisdiction on …

Foreign Account Reporting and Exchanges of Information

FATCA, treaty exchanges, and deferred prosecution agreements are some of the ways that IRS can be tipped off to your foreign accounts. Contents1 Foreign Account …

FIRPTA Withholding on Dispositions of U.S. Real Property Interests

FIRPTA witholding rules may apply to a disposition of a U.S. real property interest by a foreign person. Such transactions are subject to the Foreign …

IRS Audits of Streamlined Applications

A question that’s commonly asked by prospective clients in a streamlined compliance filing is: “will I get audited?” This article will hopefully shed some light. …

Foreign Life Insurance Taxation

Contents1 How U.S. Life Insurance Policies are Taxed2 Tax treatment of foreign life insurance policies2.1 Is it a qualifying life insurance policy?2.1.1 (1) Cash Value …

Streamlined Filing, Foreign Accounts, and Attorney’s Fees

Contents1 How much does a streamlined case cost?2 How a streamlined case is handled2.1 Step 1: Initial consultations2.2 Step 2: Research2.3 Step 3: Tax preparation2.4 …

IRS Tax Amnesty & Voluntary Disclosure Practice

Contents1 Domestic Voluntary Disclosure2 Steps for Making a Voluntary Disclosure Under the Revised Guidelines2.1 1. Make a pre-clearance request2.2 2. Submit required voluntary disclosure documents2.3 …

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

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

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

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

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

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

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

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

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

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