International Tax Law Blog Posts from Moskowitz LLP

Paul Manafort on Trial: Round One

Posted on August 19, 2018February 13, 2019 by Moskowitz LLP Posted in Criminal Tax Law, International Taxation

President Trump’s former campaign manager has been accused of hiding millions of dollars in foreign bank accounts, using international wires to fund a lavish lifestyle, and lying to banks to get loans for which he didn’t qualify. While we await the jury’s decision, here is a summary of the issues...

Foreign Account Reporting: Time Limit for IRS Action

Posted on March 9, 2018August 31, 2021 by Moskowitz LLP Posted in International Taxation, Tax Planning & Compliance, Tax: Audits, Litigation & Collection

To conduct an audit or otherwise take action on a tax return, the IRS must generally act within three years from the later of either the return’s due date or the date it was filed. That time limit may be extended to six years if there has been a “substantial...

Update on IRS Offshore Initiatives: Investigations and agreements with financial institutions worldwide

Posted on January 18, 2018February 14, 2019 by Moskowitz LLP Posted in International Taxation, Tax Planning & Compliance, Tax: Audits, Litigation & Collection

In our last post, we noted that the U.S. government goes to great lengths to identify and prosecute noncompliant taxpayers, as well as promoters and financial institutions who assist U.S. taxpayers avoid their tax obligations by hiding their offshore income and assets. Some recent plea agreements with large financial institutions...

Update on IRS Offshore Initiatives

Posted on January 16, 2018February 14, 2019 by Moskowitz LLP Posted in International Taxation, Tax Planning & Compliance, Tax: Audits, Litigation & Collection

Global tax issues are a top priority for the Internal Revenue Service Criminal Investigation Division (IRS-CI), which focuses its work on investigating taxpayers who willfully engage in tax evasion. Significant efforts are also being made to identify and take legal action against promoters and financial institutions who have assisted taxpayers...

Undisclosed Foreign Accounts, Part II

Posted on November 6, 2017February 14, 2019 by Moskowitz LLP Posted in International Taxation

This is a continuation of the first post on undisclosed foreign accounts. The executor of a decenent’s estate has a duty to act in a prudent manner and in accordance with the law. At times, this may result in having to take an unpopular position or action that angers the...

Undisclosed Foreign Accounts

Posted on November 3, 2017February 14, 2019 by Moskowitz LLP Posted in International Taxation

Serving as Executor can at times be more of a headache than an honor. On top of a pile of paperwork and dealing with a multitude of family issues, you can be sued! Executors have a number of responsibilities, most importantly payment of the decedent’s outstanding tax liabilities, debts and...

Getting Into Compliance with Your Foreign Account Reporting, Part III

Posted on March 24, 2017February 15, 2019 by Moskowitz LLP Posted in International Taxation, Criminal Tax Law

Other Posts in this Series Part I Part II When Lionel Messi was charged with tax fraud in Spain, his first line of defense was "I was playing football, I knew nothing." The court did not care that Messi signed documents handed to him by his father and advisors without...

Getting Into Compliance with Your Foreign Account Reporting, Part II

Posted on March 23, 2017February 15, 2019 by Moskowitz LLP Posted in International Taxation

Other Posts in this Series Part I Part III In Part I, we listed some of the penalties associated with the failure to report foreign accounts, and what is widely regarded as the best option for coming into compliance – the Offshore Voluntary Disclosure Program (OVDP). In this post, we...

Getting Into Compliance with Your Foreign Account Reporting, Part I

Posted on March 22, 2017February 15, 2019 by Moskowitz LLP Posted in International Taxation, Criminal Tax Law

Other Posts in this Series Part II Part III With the 2015 release of the “Panama Papers,” roughly 11.5 million documents detailing personal financial information of wealthy individuals and identifying nearly 215,000 offshore entities are now available to government authorities. That and other leaks, as well as the overall step-up...

Reporting Foreign Income: Four Common Misconceptions

Posted on March 20, 2017February 15, 2019 by Moskowitz LLP Posted in International Taxation, Tax Planning & Compliance

The U.S. government has stringent reporting requirements when it comes to foreign assets and income, but many people are still not coming into compliance based on some mistaken beliefs. Here are four common misconceptions regarding foreign income and asset reporting: #1: The income I earn in foreign countries is not...

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Category: International Taxation