Law Office Of Kunal Patel PLLC

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In the recent U.S. v. Ram Agrawal; No. 2:18-cv-00504 the district court rejected the taxpayer’s reasonable cause defense. It granted the government summary judgment in its suit to collect FBAR penalties for taxpayer’s nonwillful failure to file foreign bank account reports (FBARs) to report his Swiss bank account. The Taxpayer was very fortunate that the failures were not deemed willful. Excerpts from the court order are provided below. Case facts & background Taxpayer was born in India and moved to the United States around 1970. He is a United States citizen. He completed his graduate education in the U.S., then…
On 11/19, the IRS released a memorandum to issue interim guidance to update the process by which IRS accepts requests for confirmation (verification) that the government received a filed FinCEN Form 114 (formerly TD F 90-22.1), Report of Foreign Bank and Financial Accounts (FBAR), until IRM 4.26.16.4.13, FBAR Filing Verification, is revised. Currently, IRM 4.26.16.4.13(4) allows a filer to call the IRS FBAR hotline (1-866-270-0733, option 1) for verbal verification of up to five FBAR filings at no charge. Written requests are required for more than five verifications, for paper copies of filed FBAR reports, and for any…