FOREIGN INVESTMENTS – Compliance & Disclosure issues

Posted on by Moskowitz LLP Posted in International Taxation, Tax Planning & Compliance
As the national markets grow global, many American investors find themselves with potentially lucrative but highly complicated foreign investment opportunities. While the investments themselves and the returns thereon may be fairly simple and straightforward, the tax treatment of those investments is anything but simple and straightforward. While trying to catch...
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Passive Foreign Investment Companies and Tax Treatment – Understanding PFIC reporting

Posted on by Moskowitz LLP Posted in International Taxation
With the heightened interest in U.S. connected people and businesses in offshore banking, it is important to understand the importance of properly to the Internal Revenue Service and various State taxing agencies of foreign bank accounts and investments. The Federal income tax rules regarding those who have interest in any...
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U.S. Department of Justice and the Internal Revenue Service Expand Collection Efforts Internationally

Posted on by Moskowitz LLP Posted in Tax: Audits, Litigation & Collection, International Taxation, Tax Planning & Compliance
As individuals and companies take advantage of international tax benefits or previously undetected avenues of sheltering money from taxes and creditors, the Internal Revenue Service (IRS) is now concentrating more of its efforts on overseas tax compliance and collection. IRS Commissioner Douglas H. Shulman called global tax administration efforts a...
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2011 Voluntary Disclosure Initiative (OVDI) for Unreported Offshore Accounts

Posted on by Moskowitz LLP Posted in Criminal Tax Law, International Taxation
There has recently been a flurry of press surrounding the IRS' announcement of a new 2011 Voluntary Disclosure Initiative (OVDI) for offshore accounts. This program is part of the Department of Justice's targeting of offshore bank account holders who fail to report income associated with the account on their U.S....
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Voluntary Disclosure Initiative

Posted on by Moskowitz LLP Posted in International Taxation, Criminal Tax Law
"Last & Best" 2011 Offshore Voluntary Disclosure Initiative On February 8, 2011, the Internal Revenue Service announced the "last and best" voluntary disclosure program for those with offshore accounts.  The official name of the program is the "2011 Offshore Voluntary Disclosure Initiative" (OVDI).   This new program is scheduled to run...
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History of the Internal Revenue Service’s Voluntary Disclosure Program

Posted on by Moskowitz LLP Posted in International Taxation, Criminal Tax Law, Tax: Audits, Litigation & Collection
This is a two-part blog post on the evolution of IRS voluntary disclosure programs.  The first post traces these programs from their inception through the 1990's.  The second post discusses the programs beginning in 2000 and carrying through to the present day. Overview Since the Justice Department sued UBS in...
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IN 2010 -THE WORLD BECOMES SMALLER AND IS NOW TAX TRANSPARENT

Posted on by Moskowitz LLP Posted in Tax Planning & Compliance, International Taxation
INTERNATIONAL TAX PREPARATION FOR BUSINESSES AND INDIVIDUALS On March 18, 2010, the Foreign Account Tax Compliance Act (FATCA) was enacted into law. The scope of FATCA is extremely broad. Almost every foreign financial institution is within reach of this new law.  FATCA requires any foreign financial institution that holds any...
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