International Tax Law Blog Posts from Moskowitz LLP

Dual Status Aliens – Part II: Tax Deductions, Exemptions and Credits

Posted on September 3, 2019October 13, 2020 by Moskowitz LLP Posted in International Taxation, Tax Planning & Compliance

Dual Status Aliens are entitled to certain tax deductions, exemptions, and credits. As we noted in Part I, if you are a Dual Status Alien, you must pay taxes on your worldwide income for the part of the year that you are a resident alien and on your U.S. income...

Dual Status Aliens – Part I: Residency

Posted on August 29, 2019January 7, 2020 by Moskowitz LLP Posted in International Taxation, Tax Planning & Compliance

For U.S. taxpayers arriving or departing the country, your tax status can have a significant impact on your year-end tax bill. The U.S. is notorious for being one of the only countries in the world that taxes its citizens and permanent residents on their worldwide income. If you are a...

What Constitutes “Willful” Failure to File An FBAR?

Posted on July 2, 2019January 26, 2021 by Moskowitz LLP Posted in International Taxation, Tax: Audits, Litigation & Collection

The willful failure to file an FBAR results in higher tax penalties than the non-willful failure to do so. But how does the IRS determine that your failure to act was “willful”? The U.S. Government’s stringent foreign bank account reporting requirements are accompanied by horribly disproportionate penalties for failure to...

Keeping a Piece of You: Taxation of U.S. Citizens Living Abroad

Posted on June 20, 2019June 11, 2019 by Moskowitz LLP Posted in International Taxation, Tax Planning & Compliance

U.S. tax laws are relatively unique in that they require all U.S. citizens and resident aliens to file U.S. tax returns and pay U.S. taxes even if they are living abroad. In addition, even if they produce no interest, foreign accounts totaling $10,000 at any time during the year must...

Failure to Report Foreign Account Results in Fine of 50% of Account Balance

Posted on May 7, 2019October 13, 2020 by Moskowitz LLP Posted in International Taxation, Tax Planning & Compliance

Taxpayer liable for maximum willful FBAR penalty of 50% of account balance for failing to report foreign assets. The willful FBAR penalty battle rages on. The recent holding in Kimble vs. United States is a tremendous setback to taxpayers who have been delinquent with their foreign account reporting. Here is...

Crackdown on Israeli Banks and U.S. Expats

Posted on October 24, 2018February 25, 2019 by Moskowitz LLP Posted in Tax: Audits, Litigation & Collection, International Taxation

Israeli banks are being investigated by the U.S. government, and American expats are feeling the heat. The year 2007 marked the beginning of a major shift in world banking. It began with the UBS scandal and the dismantling of Swiss bank secrecy laws, and continued with the enactment of FATCA...

New Global Partnership Formed to Combat International Tax Crime

Posted on October 15, 2018February 13, 2019 by Moskowitz LLP Posted in International Taxation, Criminal Tax Law, Cryptocurrency Tax Assistance

Law enforcement leaders from five countries have joined efforts in their fight against international tax crime and money laundering. The new “Joint Chiefs of Global Tax Enforcement” (J5) brings together tax enforcement authorities from Australia, Canada, the Netherlands, the U.K. and the U.S. to develop new strategies in the pursuit...

The Colliot Case, Part II: $100,000 Limit on Civil FBAR Penalties

Posted on September 10, 2018February 13, 2019 by Moskowitz LLP Posted in International Taxation, Tax Planning & Compliance

In Part I, we discussed a very significant case involving a taxpayer who willfully failed to file FBARs for a number of years. Mr. Dominique Colliot objected to the extraordinary penalties assessed against him, arguing that the federal regulation used by the IRS to justify its assessment had a $100,000...

$100,000 Limit on Civil FBAR Penalties: The Colliot Case, Part I

Posted on August 30, 2018February 13, 2019 by Moskowitz LLP Posted in International Taxation, Tax Planning & Compliance

When people learn that their FBAR penalties have been set at 50% of their account balance for each year that they have been noncompliant, they get understandably upset. At a certain point, those penalties become absurd, particularly when little or no U.S. taxes were due on the foreign account in...

Paul Manafort Found Guilty

Posted on August 22, 2018February 13, 2019 by Moskowitz LLP Posted in Criminal Tax Law, International Taxation

Paul Manafort has been found guilty of eight counts of filing false tax returns, failing to file FBARs, and bank fraud. The verdict is in. The jury has found Paul Manafort, President Trump’s former campaign manager, guilty of 8 of the 18 counts charged against him. Five counts of filing...

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Category: International Taxation