Pursing a Claim for the Refund of a Penalty Paid Through an Offshore Voluntary Disclosure Program

Posted on by Moskowitz LLP Posted in International Taxation, Tax Planning & Compliance
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 Part Four: Examining the Limitations a Closing Agreement Places on Tax Litigation OVDP Penalty Refund - Setting Aside the Closing Agreement on the...
Read More

The IRS’s Position Regarding Disclosures Made Outside a Targeted Voluntary Disclosure Program

Posted on by Moskowitz LLP Posted in International Taxation, Criminal Tax Law
Other Posts in this Series A History of the IRS’s Targeted Offshore Voluntary Disclosure Programs Pursing a Claim for the Refund of a Penalty Paid Through an Offshore Voluntary Disclosure Program Part Four: Examining the Limitations a Closing Agreement Places on Tax Litigation OVDP Penalty Refund - Setting Aside the...
Read More

A History of the IRS’s Targeted Offshore Voluntary Disclosure Programs

Posted on by Moskowitz LLP Posted in International Taxation
Other Posts in this Series 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 Part Four: Examining the Limitations a Closing Agreement Places on Tax Litigation OVDP Penalty Refund - Setting...
Read More

OVDP PARTICIPANTS: CONTACT YOUR TAX ATTORNEY IMMEDIATELY – JUNE 30TH DEADLINE

Posted on by Moskowitz LLP Posted in International Taxation, Tax Planning & Compliance
The New Streamlined Filing Compliance for U.S. Persons Living Inside the U.S. and How for a Very Brief Period of Time the Participants of the OVDP may Significantly Benefit the Program Up until last week, the 2012 Streamlined Filing Compliance Procedures offered by the Internal Revenue Service ("IRS") were limited...
Read More

Foreign Bank Accounts and Other Foreign Financial Assets Reporting Regulations Take Effect July 1 2014

Posted on by Moskowitz LLP Posted in International Taxation, Tax Planning & Compliance
Part 1 While many tax reporting requirements have been in place for many years, the Foreign Account Tax Compliance Act (FATCA) set to take effect on July 1, 2014 establishes enhanced due-diligence and information reporting requirements, both for individuals and foreign banks. This will provide the IRS with an increased...
Read More

Another Way to Identify Income Underreporting – 1099K

Posted on by Moskowitz LLP Posted in Business Law, Tax Planning & Compliance
Form 1099-K is a new information return sent to businesses by "payment settlement entities" (i.e., organizations responsible for reporting payments made by credit cards) reporting the amount of credit card and other electronic receipts that were processed for the business. The IRS also receives a copy of Form 1099-K and...
Read More