Foreign Nationals & Expats

Foreign Pension Plans Under 402(b)

Classifying foreign pension plans for U.S. tax reporting can be confusing and contain many pitfalls. Further complicating matters is that other countries consider their plans …

Ninth Circuit Holds that Non-Willful FBAR penalty is Assessed Per Form

Following a string of other similar decisions, the Ninth Court Court of Appeals in United States v. Boyd finds that the non-willful FBAR penalty is …

Virginia Man is Charged with Filing False Streamlined Filing

In at least the second such instance that we’re aware of, the Government has brought charges related to filing a false streamlined submission, among other …

District Court Says Only One FBAR Penalty Per Form

After a district court in Texas recently held that penalties for the non-willful failure to file an FBAR is be assessed by form (and not …

IRS Issues Temporary Guidance for FBAR Compliance Enforecement

The IRS Small Business & Self-Employed Division updated guidance (SBSE-04-1120-0074) for foreign bank account report compliance activity due to the COVID-19 pandemic. A text of …

Taxpayers challenge IRS’s Assessment of PFIC Taxes

In a recent case before the U.S. Court of Federal Claims, two married taxpayers appeared pro se in challenging the assessment of passive foreign investment …

New IRS Campaign Targets Nonresident Rental Income

The IRS recently announced an LB&I campaign that targets nonresidents who own U.S. rental properties. Based on past experience, IRS campaigns should be taken seriously. …

Texas Court Holds that FBAR Nonwillful Penalty is Per Form, Not Per Account

In United States v. Bittner, the IRS had sought to reduce to judgment about $3M of non-willful FBAR penalties, which had been assessed per account. …

IRS Announces Section 965 Compliance Campaign

This week the IRS announced a new Section 965 compliance campaign in it’s LB&I division. While U.S. corporations have owed the vast majority Section 965 …

Court Rejects Eight Amendment Applicability to FBAR Fines

In United States v. Isac Schwarzbaum, No. 9:18-cv-81147, the U.S. District Court of the Southern District of Florida found the taxpayer liable for nearly $13M …

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 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

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

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

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

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

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. 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

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

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