The Multilateral Convention on Mutual Administrative Assistance in Tax Matters, Part IV

Posted on by Moskowitz LLP Posted in Criminal Tax Law, Tax: Audits, Litigation & Collection
Other Posts in this Series Part I Part II Part III The first three segments in this series on the Multinational Convention on Mutual Administrative Assistance in Tax Matters (the "Convention") focus on the abilities states party to the Convention enjoy.  This includes the ability to exchange information and cooperate...
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The Multilateral Convention on Mutual Administrative Assistance in Tax Matters, Part II

Posted on by Moskowitz LLP Posted in Criminal Tax Law, Tax: Audits, Litigation & Collection
Other Posts in this Series Part I Part III Part IV In Part I of this series, we provided an introduction to the Multilateral Convention on Mutual Administrative Assistance in Tax Matters (the "Convention") and described two methods of information exchange promoted by the Convention.  In Part II, we discuss...
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The Multilateral Convention on Mutual Administrative Assistance in Tax Matters, Part I

Posted on by Moskowitz LLP Posted in Criminal Tax Law, Tax: Audits, Litigation & Collection
Other Posts in this Series Part II Part III Part IV Countries have long recognized that, while tax administrations are confined to their respective jurisdictions, taxpayers function on a global level. In 1988, the Organization for Economic Cooperation (OECD) and the Council of Europe established the Multinational Convention on Mutual...
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Taxation of Convertible Virtual Currency, Part III: Reporting and Penalties for Noncompliance

Posted on by Moskowitz LLP Posted in Criminal Tax Law, Tax: Audits, Litigation & Collection
Other Posts in this Series Part I: It’s Not Money Part II: Taxation of Virtual Currency Income When it comes to Bitcoins and other convertible virtual currency, anonymity may not be all it’s cracked up to be. For one thing, an underlying assumption is that individuals who keep their financial...
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California Criminal Enforcement Task Force

Posted on by Moskowitz LLP Posted in Criminal Tax Law, State & Local Taxation
The Sacramento Bee reports that the California Board of Equalization has unveiled a website to help the public report people or companies suspected of tax evasion and other crimes in the underground economy. See Article here. (10/27/14) Agencies including the California Department of Justice, California Franchise Tax Board, and Federal...
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Offshore Bank Account Crackdown; Analysis of Recent Plea – August 2014

Posted on by Moskowitz LLP Posted in International Taxation, Criminal Tax Law
83 year-old "Hot Lips" Pleads to Federal Tax Crimes As part of our Offshore Voluntary Disclosure and Tax Compliance practice, we follow cases of interest.    Last week, the U.S. Attorney's office announced a guilty plea of conspiracy to defraud the United States and willfully failing to disclose offshore bank account...
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Contesting an IRS Summons: The Impact of United States v. Clarke

Posted on 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....
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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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