Anthony V. Diosdi, LL.M - Taxation
Senior Associate Tax Attorney
- Tax Litigation – U.S. Tax Court
- International Tax – Inbound, Outbound and Reporting
- Federal Income Tax Planning
Current Scope of Practice
Anthony is a Senior Associate Tax Attorney at Moskowitz, LLP. He focuses his practice on defending our clients in all phases of federal tax controversies and litigation, and defends clients investigated for civil and criminal offenses. Anthony engages in a nationwide practice before all divisions of the Internal Revenue Service, the civil and criminal Tax Division of the U.S. Department of Justice, the United States Tax Court, United States Claims Court, United States federal district courts in several U.S. districts, and appellate courts. As a trial attorney, he has tried and settled a significant number of cases covering the spectrum – from civil tax fraud, Section 1031 exchanges, deductions claimed by real estate professionals, securities fraud, negligence penalties, and alleged tax shelter cases.
Anthony is admitted to practice throughout the State of Florida, the State of California, the 9th Circuit Court of Appeals, the U.S. District Court for the District of Colorado, the Federal Circuit for the U.S. Court of Appeals, the U.S. Federal Court of Claims and the United States Tax Court. He is also a member of the tax sections of the Florida and California Bars and holds licenses to practice before the Internal Revenue Service.
Anthony has particularly deep experience representing clients before the Internal Revenue Service Offshore Voluntary Disclosure Program and has successfully convinced the Internal Revenue Service not to assess any offshore penalties for a substantial number of clients participating in the disclosure program. In addition, he has litigated international reporting penalties and penalties associated with not disclosing foreign financial accounts on a Form TD F 90-22.1 (Report of Foreign Bank and Financial Accounts (FBAR)) before the United States Tax Court and United States district court.
- Co-Author of “Charitable Contributions of Industrial/Commercial Property: Market Tax Benefits, plus Bargain Sales Revisited”, The Real Estate Tax Digest, Vol. 19 No. 5, (May 2001), p.15
- Co-Author of “Now since Switzerland has lost its status as a Secret Tax Haven, should the holders of Secret Swiss Offshore Accounts rush to confess to the IRS?”, San Francisco Times, Vol. 23 No. 20, (December 19-26, 2008), p.19
- “How Real Estate Investors Can Deduct Unlimited Losses”, Commercial Property, (January/February 2009), p.7
- “Benefit Using the LLC”, A.D. Kessler’s Creative Real Estate Magazine, (March 2009), p.14
- “The Unintended Consequences of Section 1706 and Possible Solutions”, ebookpedia net, (February 18, 2010)
- “U.S. Taxation of Fideicomisos under FATCA Rules”, JD Supra, (August 8, 2012) Quoted by a number of foreign investment websites
- “Non-Citizens Risk Immigration Status for Offshore Bank Accounts”, JD Supra, (August 23, 2013)
- “U.S. Tax Effects of Treaties in the Context of Foreign Investment in the U.S.”, JD Supra, (September 7, 2012)
- “Just How is Expatriation Tax Calculated”, JD Supra, (September 12, 2012) Quoted by the Canada Free Press, December 23, 2013
- “District Court Decides FBAR Penalty Assessment Case - Both A Win For The Government & For OVDP Participants”, JD Supra, (November 26, 2012)
- “The State of California Seeks Back Taxes From Small-Business Shareholders - Not So Fast”, JD Supra, (February 14, 2013)
- “A Closer Look at the Non-Willful FBAR Penalty,” California Tax Lawyer, (February 2013)
- “Collection Due Process Hearing: Is it a Second Chance For Taxpayers To Litigate A Matter Previously Litigated”, JD Supra, (April 1, 2013)
- “What a Tax Attorney Can Do for You: Understanding How Apple, Inc. Legally Does not Pay Income Tax”, JD Supra, (May 22, 2013) Named as one of the most read articles by JD Supra
- “The Government Shut Down - Great News for Some Taxpayers”, JD Supra, (October 7, 2013)
- “The Qualified Quiet Disclosure: Operating Outside of The IRS Offshore Voluntary Disclosure Initiative”, JD Supra, (November 13, 2013)
Anthony obtained a Bachelor of Arts from Florida Atlantic University, followed by his Juris Doctor from Quinnipiac University School of Law in 1998. In 2000, Anthony received his LL.M. in Taxation from Golden Gate University School of Law.
Prior to joining Moskowitz, LLP, Anthony worked as a tax accountant with the international tax practice of PricewaterhouseCoopers. Anthony’s prior experiences as true tax litigator and a tax accountant with a major accounting firm add to the diversity of Moskowitz, LLP’s tax practice. His combination of years of tax litigation representation and tax compliance work enables him to provide comprehensive tax planning to our clients. In particular, Anthony has advised our clients on a variety of issues such as assisting U.S. companies seeking relief using remedies under tax treaties, pre-immigration tax planning, tax planning for U.S. corporations doing business abroad, and mitigation of taxes on shares of Passive Foreign Investment Companies