Form 5471 Basics
Everything you need to know about foreign corporation reporting to avoid problems.
The Top Form 5471 Reporting Mistakes to Avoid
There are many common errors in foreign corporation reporting that can be avoided.
Meet Mr. Patel
Mr. Patel’s expertise is in all stages of tax controversies including international tax
law, foreign bank account
Mr. Patel is a graduate of Georgetown (J.D.) and New York University (LL.M tax) law schools, which are the top 2 tax law schools in the United States. Mr. Patel is a Board Certified Tax Law Attorney, Board Certified Estate Planning Law Specialist, Board Certified Elder Law Attorney, and frequent speaker on legal issues affecting tax, offshore tax planning, and estate planning.
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About Us
Patel Law Offices’ goal is to achieve our clients’ objectives in the most creative, responsive, and cost-effective manner.
Our International Tax Attorney team represents clients nationwide and globally in IRS offshore and voluntary disclosure solutions. We have counseled clients in over 1000 voluntary disclosure matters and are one of the most experienced IRS offshore and voluntary disclosure law firms.
Each case is led by Mr. Patel, who is a Board Certified Tax Law Lawyer. Our International Tax Attorney team concentrates in IRS offshore and voluntary disclosure solutions for undisclosed accounts, assets and investments including Streamlined Domestic Offshore Procedures (SDOP), Streamlined Foreign Offshore Procedures (SFOP), Voluntary Disclosure Practice (VDP), Delinquent International Information Return Submission Procedure (DIIRSP), Delinquent FBAR
Reviews
Nicholas Visco ★★★★★
Extremely knowledgeable and well versed in probate matter. Mr. Patel and his team have been excellent to work with.
Rahul Sharma ★★★★★
Parag provided both professional and personal advice in a super timely manner. Would definitely recommend and work with again in the future.Latest Blog Posts
Parag Patel Esq. Speaks at Annual Convention of New Jersey Society of Certified Public Accountants
Parag Patel Esq. will be a featured speaker at the annual state convention of the New Jersey Society of Certified Public Accountants (NJCPA) on June 3-6, 2025 in Atlantic City, NJ. The seminar is entitled “2025 Tax Planning Essentials: Strategies for Accountants”. Mr. Patel will discuss effective strategies to recognize and help m…
Parag Patel Esq. speaker at the National Association of Enrolled Agents (NAEA) Seminar “2025 Mid-Year Update”
Parag Patel Esq. is a featured speaker at the National Association of Enrolled Agents (NAEA) Seminar entitled “2025 Mid-Year Update” on June 10, 2025. Seminar description is below: “2025 Mid-Year Update” This informative seminar explores tax law changes for 2025, equipping tax professionals with practical strategies to manage new compliance requirements and optimize…
Navigating the Puzzle: Understanding Form 8938 Audit Triggers
It’s important to be aware of the caution and risks associated with foreign banks reporting balances to the IRS, particularly in the context of Form 893
Navigating Inheritance: The Step-Up in Basis and Recognizing Implied Life Estates After Death
Understanding the Step-Up in Basis Under Internal Revenue Code Section 1014(a), the basis of inherited property is stepped up to its fair market value (FMV) at the time of the decedent’s death. This means that when the heir sells the asset, any appreciation before the decedent’s death escapes capital gains tax. The “step-u…
Common Problems Solved
Streamlined Domestic Offshore Procedures (SDOP)
The Streamlined
Domestic Offshore Procedures is one of the two popular programs available
under the IRS
Streamlined Filing Compliance Procedures. It is for U.S. Resident Taxpayers
who originally filed income tax returns, but were non-willful
in not reporting foreign accoun
Streamlined Foreign Offshore Procedures (SFOP)
The Streamlined
Foreign Offshore Procedures is one of the two popular programs available
under the IRS
Streamlined Filing Compliance Procedures. Applicants need not have
filed original tax returns, but they must be non-willful
in not reporting foreign accoun
Delinquent International Informational Return Submission Procedures (DIIRSP)
The DIIRSP is one of the four methods for taxpayers with unreported offshore accounts to become compliant. Taxpayers who have failed to file certain international-related information returns including Forms 5471, 8938, 3520, 8865, 926, 5472, an 8858 can use the DIIRSP to cure the non-compliance. No penalties are applied if there is reasonable cause for the failure to file the information form and the IRS agrees. Reasonable Cause is a fact specific submission, which is based on each applicant's facts and circumstances.
Delinquent
FBAR Submission Procedure (DFSP)
The FBAR
Form 8938 Penalties
A delinquent or late Form
8938 Statement of Foreign Financial Assets is subject to many common
mistakes and high penalties.
Our legal team cures many common Form 893
Form 5471 Penalties
U.S. owners and investors of certain foreign corporations must
file a Form 547
Malta Pension Plan Problems
Malta Pension Plans have been criminally and civilly investigated by the IRS and are on the IRS "dirty dozen" list. Recently in late 2021, the United States and Malta entered an agreement regarding Malta pension rollovers. We have assisted dozens of taxpayers with compliance and solutions with Malta Pension Plan problems.