Subpart F: Taxation of Foreign Income Earned by U.S.-Controlled Foreign Corporations

Posted on by Moskowitz LLP Posted in Business Law, International Taxation
In 2012, Google made headlines when it was revealed that the multinational company had avoided approximately $2 billion in worldwide income taxes the previous year by funneling the equivalent of 80% of the company's pre-tax profit through a Bermuda shell company. The tax avoidance techniques used by the company (the...
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Why a Tax Attorney’s Advice is Important: Case Study – Cavallaro

Posted on by Moskowitz LLP Posted in Estate Planning & Taxation, Tax Planning & Compliance, Tax: Audits, Litigation & Collection
Estate Planning, Gift Tax, Business Succession, and the Ability to Rely on Advice of Counsel JD Supra Business Advisor recently published our case study on the Tax Court Opinion in the Cavallaro matters - a true rags to riches story involving taxation, and why a tax attorney's advice/representation is important....
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Appeals Judicial Approach and Culture (AJAC) Project, Part II

Posted on by Moskowitz LLP Posted in Tax Planning & Compliance, Tax: Audits, Litigation & Collection
Collection Due Process and Offers in Compromise In Part I of this series, we introduced the Appeals Judicial Approach and Culture (AJAC) Project and new guidelines for tax appeals. We also discussed the importance of having an independent IRS appeals process and noted that with limited exceptions, the government is...
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Why a Tax Attorney’s Advice is Important: Estate Planning, Gift Tax, Business Succession, and the Ability to Rely on Advice by Counsel

Posted on by Moskowitz LLP Posted in Estate Planning & Taxation, Tax Planning & Compliance
Case of the Week: Cavallaro A recently published tax court opinion provides us with a fascinating case involving a rags to riches story of a tightly-knit hardworking family and the creation, merger and eventual sale of two related family companies. It hit our radar because of the impermissible tax position...
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