Moskowitz LLP, Author at Moskowitz LLP

The Fine Line between Tax Evasion and Tax Avoidance

Posted on August 27, 2014February 18, 2019 by Moskowitz LLP Posted in Tax Planning & Compliance, Criminal Tax Law

The Fine Line between Tax Evasion and Tax Avoidance Any one may so arrange his affairs that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to increase one's taxes....

Tax Planning Summer 2014

Posted on August 21, 2014February 18, 2019 by Moskowitz LLP Posted in Tax Planning & Compliance

Dear Valued Clients, I hope you are enjoying your summer. Summertime is the perfect time for tax planning. There's enough of the year behind you to establish a track record, AND still enough ahead to make changes that matter. Moskowitz LLP can help you to identify the right tax-saving opportunities...

Reporting Gifts and Inheritances Received from Abroad

Posted on August 16, 2014February 18, 2019 by Moskowitz LLP Posted in International Taxation, Tax Planning & Compliance

Many people make the mistake of failing to report gifts or bequests from abroad on tax returns, because they do not think gifts are "income". This can be a costly mistake, however, subjecting the recipient to hefty tax penalties which could easily have been avoided with some qualified tax advice....

Contesting an IRS Summons: The Impact of United States v. Clarke

Posted on August 13, 2014February 18, 2019 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....

Corporate Inversion – Assertive Tax Planning & Political Concerns

Posted on August 12, 2014February 18, 2019 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...

The Corporate Inversion: From Obscure Strategy to Hot Trend

Posted on August 8, 2014February 18, 2019 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...

No Easy Exit: The U.S. Expatriation Tax

Posted on August 7, 2014February 18, 2019 by Moskowitz LLP Posted in International Taxation, Tax Planning & Compliance

As US Citizenship gets increasingly expensive, more individuals and families are leaving the United States - many of them for good. However, there is no easy exit from the IRS and those considering expatriation are advised to obtain tax help before taking the plunge. What is the Expatriation (Exit) Tax?...

Tax Inversions: Tax Savings Strategies for Corporations and What Political Calls for Tax Reform Mean

Posted on August 6, 2014February 18, 2019 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...

Can an OVDP Participant Set Aside a Closing Agreement on the Theory of Duress?

Posted on July 14, 2014February 18, 2019 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...

Examining the Limitations a Closing Agreement Places on Tax Litigation

Posted on July 10, 2014April 1, 2022 by Moskowitz LLP Posted in International Taxation, Tax: Audits, Litigation & Collection

Other Posts in this Series A History of the IRS’s Targeted Offshore Voluntary Disclosure Programs The IRS's Position Regarding Disclosures Made Outside a Targeted Voluntary Disclosure Program Pursing a Claim for the Refund of a Penalty Paid Through an Offshore Voluntary Disclosure Program OVDP Penalty Refund - Setting Aside the...

How can we help you today?