Anthony V. Diosdi

Senior Associate

San Francisco, CA
Phone: (415) 394-7200 Fax: (415) 398-6501

Email: Anthony V. Diosdi

Overview   Experience   Insights

Anthony V. Diosdi is a Senior Associate at Moskowitz LLP. He represents clients in all stages of international and federal tax controversy from audits through appellate litigation and advises clients on the implementation of tax risk management. With a practice focused on federal tax controversy, Anthony has exceptional experience in tax litigation and international taxation. In addition, Anthony has represented hundreds of clients in voluntary disclosures, FBAR Penalty exams, and civil and criminal tax investigations related to unreported foreign bank accounts. Anthony works extensively on both Internal Revenue Service civil and criminal investigations of undisclosed foreign bank accounts. Before joining Moskowitz LLP, Anthony prepared global tax returns for high net-worth individuals with a Big Four Accounting Firm.

Anthony practices in the areas of tax controversy, federal litigation, and international taxation. Anthony is one of a select group of tax litigators who has litigated FBAR penalty controversies and may be the only person who has ever successfully contested an FBAR penalty under the Administrative Procedure Act. Anthony has served as lead or co-counsel in federal district court and federal court of appeals cases throughout the United States involving tax controversies, employment tax controversies, SEC securities litigation, diversity controversies, and post-employment covenants not to compete (including the successful litigation in district court for the Northern District of Georgia proceeding of first impression adjudicating the enforceability of a forum select clause and covenant not to compete controversy. This case was named in the California Labor and Employment Bulletin as one of the top ten California Trade Secrets and Unfair Competition Developments in 2015).

Anthony has also served as lead counsel with respect to domestic and international client matters involving United States Tax Court proceedings (including issues in which motions where filed with the court to exclude Internal Revenue Service Criminal Investigators from trial and the exclusion of privileged documentary evidence), Internal Revenue Service criminal investigations, and Internal Revenue Service civil examinations. In the area of offshore compliance, Anthony has represented hundreds of clients in making a multitude of voluntary disclosures to the Internal Revenue Service.

Finally, Anthony advises U.S. businesses and individuals along with foreign based businesses and individuals in connection with international tax planning and global tax projects including intangible property migration, Foreign Investment in Real Property Tax Act (“FIRPTA”), subpart F planning, and cross-border transactions (including PFICs, foreign currency, transfer pricing, and income tax treaties).

Publications

A Closer Look at the Non-Willful FBAR Penalty, California Tax Lawyer, 2013

Can an OVDP Participant Set Aside a Closing Agreement on the Theory of Duress?, JD Supra, July 2014

The Qualified Quiet Disclosure: Operating Outside of the IRS Offshore Voluntary Disclosure Initiative, JD Supra, November 2013

Collection Due Process Hearings: Is it a Second Chance for Taxpayers to Litigate a Matter Previously Missed?, JD Supra, April 2013

The Government Shutdown- Great News for Some Taxpayers, JD Supra, October 7, 2013

What a Tax Attorney Can Do for You: Understand how Apple Inc. Legally Does Not Pay Income Tax, May 22, 2013

The State of California Seeks Back Taxes from Small Business Shareholders- Not So Fast, February 14, 2013

The Unintended Consequences of Section 1706: ebookpedia net, February 2010

Benefit Using the LLC: A.D. Kessler’s Creative Real Estate Magazine, March 2009

How Real Estate Investors Can Deduct Unlimited Losses, Commercial Property, January 2009

Should Holders of Swiss Offshore Accounts Rush to Confess to the IRS, San Francisco, Business Times, December 2008

Co-author of Charitable Contributions of Industrial/Commercial Property: Market Tax Benefits, Plus Bargain Sales Revisited Vol. 19, No. 5, The Real Estate Tax Digest, May 2001

Professional Development and Continuing Education Provided to Other Lawyers

Advanced Strategies for Challenging FBAR Penalties: Using Administrative Procedures Act in Defending Against Assessments, Strafford Webinar, July 26, 2017

Offshore Banking Disclosure Update, West Legal Education, Webinar, November 13, 2014

Captive Insurance, West Legal Education, Webinar, December 16, 2014

Tax Inversions: A Tax Saving Strategy for Corporations and What Calls for Reform Mean, West Legal Education, Webinar, November 15, 2014

Webinars:

  • Captive Insurance, Webinar, West Legal EdCenter, Nov. 13, 2014
  • Tax Inversions: Tax Savings Strategies for Corporations and What Political Calls for Tax Reform Mean, West Legal EdCenter, Aug. 2014

Speaking

  • Westlaw, Captive Insurance- Risk and Tax Advantages, December 16, 2014
  • Westlaw, Corporate Inversions, November 15, 2014.

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Education

B.A., Florida Atlantic University, 1994
J.D., Quinnipiac University, 1998
LL.M., Golden Gate University, 2000

Bar Admissions

Florida [active]

Court Admissions

Supreme Court of Florida
Ninth Circuit Court of Appeals
Federal Court of Appeals
District Court of Colorado
Court of Federal Claims
United States Tax Court

Practice Areas

  • Tax Litigation
  • Tax Controversy
  • International Tax
  • Criminal Tax
  • Federal Income Tax Planning and Compliance
  • SEC Defense and Litigation

Language

Magyar(Hungarian)

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