Moskowitz LLP, Author at Moskowitz LLP

Non-Citizens Risk Immigration Status for Offshore Bank Accounts

Posted on August 22, 2012February 19, 2019 by Moskowitz LLP Posted in International Taxation

The increased focus by the IRS on foreign income has generated a lot of news and a slew of criminal prosecutions. While US citizens need to consider the possibility of monetary penalties or a long prison sentence, resident non-citizens (green card holders) also need to worry about the possibility of...

Federal Tax Crimes: Korean Roofer Sentenced to 3 1/2 years

Posted on August 22, 2012February 19, 2019 by Moskowitz LLP Posted in Criminal Tax Law

On Wednesday, August 8, 2012, Tae Son Lee (aka, Mike Lee), age 52, of Oakland, California was sentenced to three and a half years in prison for Federal Tax Crimes stemming from his roofing business, also in Oakland, CA. The Internal Revenue Service (IRS) conducted an investigation stemming from his...

U.S. Taxation of Fideicomisos under the FATCA Rules

Posted on August 7, 2012February 19, 2019 by Moskowitz LLP Posted in Tax: Audits, Litigation & Collection

Overview of Fideicomisos If you own a home or a vacation home in Mexico, chances are that your property is held in a fideicomiso. A fideicomiso is a contractual arrangement that is arguably something in between a trust and a custodial agreement. Under Mexican law, a fideicomiso is a written...

Tax Return Preparers, Crimes, and Penalties

Posted on August 2, 2012February 19, 2019 by Moskowitz LLP Posted in Criminal Tax Law, Tax Planning & Compliance, Tax: Audits, Litigation & Collection

with thanks to Elizabeth E. Prehn, Law Clerk The Internal Revenue Service and lawmakers across the nation have introduced a bill to Congress to Increase Tax Preparer Penalties. While this bill, introduced as the Fighting Tax Fraud Act, is aimed at blatant schemes by tax preparers to defraud taxpayers, it...

United States and South Korea Coordinate to Combat Monetary & Tax Crimes

Posted on August 2, 2012February 19, 2019 by Moskowitz LLP Posted in International Taxation

To combat money and tax crimes, such as tax evasion and money laundering, the United States and Korean Governments have committed to a simultaneous criminal investigation program, SCIP. The arrangement allows the respective tax departments; the United States’ Internal Revenue Service (IRS) and South Korea’s National Tax Service (NTS), to...

Why Am I Being Audited?

Posted on July 20, 2012February 19, 2019 by Moskowitz LLP Posted in Tax: Audits, Litigation & Collection

Why Am I Being Audited? Often asked in mournful tones, it's a question we hear from new clients all the time: "Why am I being tortured with an audit?" Here is a look at a couple reasons why you may be facing an IRS audit: 1. Matching notices: A matching...

Franchise Tax Board’s Automatic Calls – What You Need to Know

Posted on July 12, 2012February 19, 2019 by Moskowitz LLP Posted in State & Local Taxation

On July 10, 2012, the California State Franchise Tax Board (FTB) announced that it would implement an automatic dialer system to make outbound calls to individuals to further enhance their collection efforts; which include, but are not limited to, tax liens, bank levies, garnishments ,etc. Businesses will begin to receive...

FBAR Filing Deadline – Receipt on or before June 30

Posted on June 26, 2012February 19, 2019 by Moskowitz LLP Posted in International Taxation, Tax Planning & Compliance

Foreign Bank Account Report, Treasury Department Form 90-22.1 (FBAR) Who Must File an FBAR: Generally, every U.S. person with a financial interest in or signature or other authority over, any financial account outside of the United States, must file an FBAR if the aggregate value of all accounts exceeds $10,000...

IRS is releasing new guidelines for 2012 OVDP

Posted on June 19, 2012February 19, 2019 by Moskowitz LLP Posted in International Taxation

The Internal Revenue Service will be providing new guidelines to the Offshore Voluntary Disclosure Program (OVDP) which address such issues as the number of years at issue (there has been much debate amongst tax attorneys as to whether it is 3, 6, 8, or more). We also expect it to...

Lauryn Hill’s unfiled tax returns leads to criminal charges

Posted on June 12, 2012February 19, 2019 by Moskowitz LLP Posted in Criminal Tax Law

On June 7, 2012, Grammy winner Lauryn Hill was indicted for failing to file back income tax returns with the Internal Revenue Service. The criminal information charges that Ms. Hill failed to file income tax returns for tax years 2005, 2006, and 2007. Typically having unfiled tax returns will not...

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