FTB joint investigation results in San Diego woman’s tax evasion plea Adds fuel to SB1185 – State Agency collaboration in Super Centralized Intelligence Partnership

A recent high profile felony state of California income tax evasion case adds fuel to the State's movement in developing a multi-agency partnership, to be known as the Centralized Intelligence Partnership.   This centralized agency will be used for the State of California to combat unreported and underreported economic activity. This...

Is Steven Seagal Above the Law when it comes to his tax debt?

Since the State started publishing the names of the individuals who owe the largest amounts, the FTB has collected more than $100 million in delinquent tax debt. Because of the amounts collected, California has gotten even more aggressive with their efforts. For instance, a new state law (AB 1424, Perea),...

Offshore Amnesty Penalties: An Unfortunate Driving Force for Renouncing Citizenship

Moskowitz LLP, A Tax Law Firm, regularly counsels individuals with foreign connections on U.S. taxation issues, facing offshore amnesty penalties. Here in San Francisco and the Silicon Valley, in particular, and California in general, we have recently seen an increase in individuals considering renouncing their U.S. citizenship1 and green cards...

U.S. Tax Effects of Treaties in the Context of Foreign Investment in the U.S.

Introduction Foreign investors in the U.S. tend to have the same goals as their U.S. counterparts. Like U.S. taxpayers, foreign investors seek to minimize their income tax liabilities associated with their U.S. real estate and business investments. However, foreign investor’s objectives are clouded by the fact that they are not...

Piercing Asia – U.S. Offshore Bank Account Crackdown results in data on undeclared bank accounts with Hong Kong Connections

On August 20, 2012, the United States Attorneys Office issued a press release regarding their most recent Offshore Bank Account Plea Agreement reached.   The taxpayer, Jacquez Wajsfelner pled guilty to willfully failing to file foreign bank account reports (FBAR) for several Swiss Bank Accounts. Slightly outside the average age of...