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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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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Examining the Limitations a Closing Agreement Places on Tax Litigation

Posted on by Moskowitz LLP Posted in International Taxation, Tax: Audits, Litigation & Collection
Other Posts in this Series A History of the IRS’s Targeted Offshore Voluntary Disclosure Programs The IRS's Position Regarding Disclosures Made Outside a Targeted Voluntary Disclosure Program Pursing a Claim for the Refund of a Penalty Paid Through an Offshore Voluntary Disclosure Program OVDP Penalty Refund - Setting Aside the...
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Pursing a Claim for the Refund of a Penalty Paid Through an Offshore Voluntary Disclosure Program

Posted on by Moskowitz LLP Posted in International Taxation, Tax Planning & Compliance
Other Posts in this Series A History of the IRS’s Targeted Offshore Voluntary Disclosure Programs The IRS's Position Regarding Disclosures Made Outside a Targeted Voluntary Disclosure Program Part Four: Examining the Limitations a Closing Agreement Places on Tax Litigation OVDP Penalty Refund - Setting Aside the Closing Agreement on the...
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The IRS’s Position Regarding Disclosures Made Outside a Targeted Voluntary Disclosure Program

Posted on by Moskowitz LLP Posted in International Taxation, Criminal Tax Law
Other Posts in this Series A History of the IRS’s Targeted Offshore Voluntary Disclosure Programs Pursing a Claim for the Refund of a Penalty Paid Through an Offshore Voluntary Disclosure Program Part Four: Examining the Limitations a Closing Agreement Places on Tax Litigation OVDP Penalty Refund - Setting Aside the...
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A History of the IRS’s Targeted Offshore Voluntary Disclosure Programs

Posted on by Moskowitz LLP Posted in International Taxation
Other Posts in this Series The IRS's Position Regarding Disclosures Made Outside a Targeted Voluntary Disclosure Program Pursing a Claim for the Refund of a Penalty Paid Through an Offshore Voluntary Disclosure Program Part Four: Examining the Limitations a Closing Agreement Places on Tax Litigation OVDP Penalty Refund - Setting...
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OVDP PARTICIPANTS: CONTACT YOUR TAX ATTORNEY IMMEDIATELY – JUNE 30TH DEADLINE

Posted on by Moskowitz LLP Posted in International Taxation, Tax Planning & Compliance
The New Streamlined Filing Compliance for U.S. Persons Living Inside the U.S. and How for a Very Brief Period of Time the Participants of the OVDP may Significantly Benefit the Program Up until last week, the 2012 Streamlined Filing Compliance Procedures offered by the Internal Revenue Service ("IRS") were limited...
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