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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Examining the Limitations a Closing Agreement Places on Tax Litigation

Posted on 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...
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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...
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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...
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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...
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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...
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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...
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