Crackdown on Tax Treaty Abuses

Posted on by Moskowitz LLP Posted in Tax: Audits, Litigation & Collection, Business Law, Tax Planning & Compliance
Tax authorities throughout the world are cracking down on taxpayers – individuals and corporations – that utilize some aggressive tax planning strategies. While most of these schemes are perfectly legal and merely take advantage of loopholes in the international tax system, there is a growing concern that they not only...
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Contesting an IRS Summons: The Impact of United States v. Clarke

Posted on by Moskowitz LLP Posted in Tax: Audits, Litigation & Collection, Criminal Tax Law
The Supreme Court recently issued a brief but significant ruling concerning a taxpayer's right to contest an IRS summons. Per 26 U.S.C. 7602, the IRS has a right to request information from a taxpayer through examination of books, papers, records, testimony, etc. pursuant to a civil or criminal IRS investigation....
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Corporate Inversion – Assertive Tax Planning & Political Concerns

Posted on by Moskowitz LLP Posted in Business Law, Tax Planning & Compliance
Our recent article published, The Corporate Inversion: From Obscure Strategy to Hot Trend addresses why many businesses and longstanding American icons have made the move towards corporate inversion, a tax reduction method of re-incorporating a company in another country if a significant portion of the company's income is derived from...
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The Corporate Inversion: From Obscure Strategy to Hot Trend

Posted on by Moskowitz LLP Posted in Business Law, Tax Planning & Compliance
Capitalist ideals of “free enterprise” and “competition” make great debate topics, but when compared to the business-friendly tax codes of other nations the United States Tax Code cannot compete. With the highest corporate income tax rate in the developed world, many businesses and longstanding American icons have made the move...
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Tax Inversions: Tax Savings Strategies for Corporations and What Political Calls for Tax Reform Mean

Posted on by Moskowitz LLP Posted in Business Law, Tax Planning & Compliance
Corporate inversion is defined as an international corporation reincorporating in a different country, changing from a U.S. corporation to an offshore jurisdiction that is usually a tax haven and therefore potentially reducing tax liability. U.S. Corporations have availed themselves to the policy and have reaped the rewards of lower tax...
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Can an OVDP Participant Set Aside a Closing Agreement on the Theory of Duress?

Posted on by Moskowitz LLP Posted in International Taxation, Criminal Tax Law, Tax: Audits, Litigation & Collection
I. Introduction and History of the Targeted Offshore Voluntary Disclosure Programs Offered by The IRS It has been just over five years since the Internal Revenue Service (“IRS”) offered the first of three offshore voluntary disclosure programs for individuals with undisclosed foreign financial accounts. Since the announcement of the first...
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