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Form 3520 Basics

Everything you need to know about Form 3520 reporting to avoid problems

The Top Form 3520 Mistakes to Avoid

There are many common errors in Form 3520 reporting that can be avoided.

Frequently Asked Form 3520 Questions

Frequently asked questions about Form 3520 and filing.

Correcting Common Form 3520 Errors

The US government has solutions to correct Form 3520 errors.

Meet Mr. Patel

Mr. Patel’s expertise is in all stages of tax controversies including international tax law, foreign bank accounts and disclosures, tax audit defense, and tax appeals. Mr. Patel has counseled over 1000 voluntary tax matters for assets before the US Internal Revenue Service.

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 Submission Procedure (DFSP).

Reviews

navnit patel ★★★★★

Parag Patel is an excellent tax lawyer. He is a very approachable and answers all questions in detail and in a way that is easy to understand. If you have any offshore tax issues he is the guy you want to talk to. Highly recommended by me and my family.

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

Do Inherited Foreign Assets Receive a Step-up in Cost Basis for U.S. Tax Purposes?


A common question asked by clients when receiving an inheritance from outside the United States is about the U.S. cost basis and receiving a step-up in basis on foreign assets owned by a non-U.S. person. Understanding the U.S. cost basis is important when assets are eventually sold as gains may …

Forms 5471, 5472, 3520 Partial Penalty Relief Still Available for 2019 and 2020 Returns


IRS Notice 2022-36 provided relief for certain taxpayers from certain failure to file penalties and certain international information return penalties with respect to tax returns for tax years 2019 and 2020 that are filed on or before September 30, 2022. Post Sep 30, 2022 Options Taxpayers who missed the September 30 filing dea…

Parag Patel Esq. speaks at New Jersey Society of Certified Public Accountants (NJCPA) Annual Tax Seminar: “A New Foreign Frontier: Foreign Income & Asset Reporting Update”.


Parag Patel Esq. will be a featured speaker at a New Jersey Society of Certified Public Accountants (NJCPA) Seminar entitled “ A New Foreign Frontier: Foreign Income & Asset Reporting Update ” on November 18, 2022. Seminar Summary: The IRS is aggressively targeting taxpayers with unreported foreign accounts and income. Tax pro…

IRS Announces Increased 2023 Gift Tax Annual Exclusion, Gift, and Estate Tax Exemptions


The Internal Revenue Service recently released the annual inflation adjustments for tax year 2023, which include welcome increases for wealth transfer tax planning. The gift tax annual exclusion will increase for the second year in a row, rising to $17,000 per recipient in 2023 (up from $16,000 in 2022). This mean…

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 accounts, investments or income, who can use Form 14654 Certification by U.S. Person Residing in the U.S. to become compliant. This limited tax amnesty solution for U.S. resident taxpayers holding noncompliant foreign accounts has a reduced single year 5% offshore penalty. Our legal team has advised and prepared hundreds of Streamlined cases with the IRS.

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 accounts, investments or income, via Form 14653 Certification by U.S. Person Residing Outside of the U.S. to become compliant. This limited tax amnesty solution for U.S. non-resident taxpayers holding noncompliant foreign accounts has a 0% penalty. Our legal team has advised and prepared hundreds of Streamlined cases with the IRS.

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 is the FinCEN Form 114, which is commonly misunderstood. A delinquent or late FBAR is subject to very high penalties. The DFSP is one of the four methods for taxpayers with unreported offshore accounts to become compliant. Taxpayers who have failed to an FBAR can use the DFSP to cure the non-compliance. While there is no DFSP penalty the DFSP has complex rigid eligibility requirements. Our legal team mitigates foreign account FBAR mistakes for clients around the globe.

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 8938 errors for clients around the globe.

Form 5471 Penalties

U.S. owners and investors of certain foreign corporations must file a Form 5471, otherwise there are very high Form 5471 Penalties. Form 5471 is a complex form with many common mistakes. because of the expansive disclosure of corporation's assets, liabilities and equity. Our legal team can help you fix late or unfiled Form 5471 errors.