Anthony V. Diosdi is a Senior Associate at Moskowitz LLP. His focus is on U.S. international tax, litigation, and tax controversy. Anthony brings a wealth of international tax and controversy experience to Moskowitz LLP. Prior to joining Moskowitz LLP, Anthony was an international tax practitioner with a Big Four accounting firm and he worked in Singapore at one of the largest law firms in Asia where he assisted in matters involving international intellectual property disputes.
See Experience page for more information
His experience enables him to provide comprehensive advice on a variety of international tax planning and compliance issues. In this context, Anthony assists clients with global tax minimization, subpart F planning, treaty issues, offshore income tax reporting, Passive Foreign Investment Companies (“PFIC”), and foreign tax compliance issues. In addition, he has assisted hundreds of clients in the making of a multitude of offshore voluntary disclosures to the Internal Revenue Service dating back to 2005.
Besides assisting clientele in matters of international compliance and planning, Anthony has extensive litigation experience. He has served as lead or co-counsel appearing pro-hac vice in federal district courts, Courts of Appeals and state court cases throughout the United States involving disputes with the United States Department of Justice, Securities and Exchange Commission, private counsel, and state taxing agencies. Recently, Anthony was one of the few attorneys that have challenged in court the manner in which the Internal Revenue Service examiners determine, calculate, and assess Foreign Bank and Financial Accounts (“FBAR”) penalties. As a result, the IRS issued new guidance to its examiners for determining, calculating, and assessing FBAR penalties. See SBSE-04-0515-0025.
In addition to international tax matters and litigation, Anthony has over 15 years of experience handling Internal Revenue Service tax controversies. In particular, Anthony has litigated a significant number of tax controversies before the United States Tax Court involving disputes with the Internal Revenue Service. He has represented clients before Internal Revenue Service examination cases and appeals. Anthony’s representation of clients before the IRS is not limited to civil cases. He has also represented clients before the Internal Revenue Service Criminal Investigation Division who were accused of crimes related to federal tax evasion, tax fraud, money laundering, wire fraud, failing to file an FBAR, and structuring.
Finally, Anthony has authored or co-authored tax articles in a number of publications. See his Insights page for more information.