Foreign Nationals & Expats

New Exemptions & Penalty Relief for Form 3520 and 3520-A

In early March 2020, the IRS released Rev. Proc. 2020-17 which provides an exemption from the information reporting requirements under IRC § 6048 – specifically, …

Government Seeks $2.7 million after Incomplete Offshore Disclosure

If you have undisclosed foreign accounts, perhaps the only thing worse than not coming forward voluntarily is submitting an incomplete disclosure. In United States v. …

Former CPA Charged with Filing False Streamlined Submission

From the DOJ press release. A federal grand jury returned a superseding indictment charging Brian Booker, a former resident of Fort Lauderdale, Florida, whose business …

IRS Again Asserts Multiple Non-Willful FBAR Penalties

Just when it seemed that things couldn’t get any stranger in the world of foreign accounts compliance… In United States v. Bittner, No. 19-cv-00415 (ED …

Is Summary Judgment Appropriate for FBAR Willfulness Finding?

In United States v. Horowitz, an OVDI/OVDP “opt out” case, the Taxpayer appeals a summary judgment decision involving FBAR willfulness penalties. Facts Taxpayers are married …

Court Finds that FBAR Penalties Can Be Assessed After Taxpayer’s Death

Can the IRS assess penalties against a deceased taxpayer for previously failing to file an FBAR? And who can the government collect the penalties from …

Government Seeks to Collect $1.1 Million for Unreported Swiss Accounts

In U.S. v. Kochav, case number 9:19-cv-80648, the Government seeks to reduce a $1.1 million willful FBAR civil penalty assessment to judgment. It’s helpful for …

Court Sustains Non-willful FBAR Penalty on Per Account Basis

Can FBAR penalties be assessed on a per account basis? In the recent United States v. Boyd, the court answered that question when it found …

IRS Announces New International 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 …

U.S. Tax Treatment of U.K. Pension Plans

Few things are more confusing for U.K. foreign nationals and U.S. expats residing in the U.K. than the U.S. tax code, especially as it applies …

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

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 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 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

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 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

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

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 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

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