International Tax Law Blog Posts from Moskowitz LLP

IRS Continues Offshore Bank Account Crackdown in 2013

Posted on January 10, 2013February 19, 2019 by Moskowitz LLP Posted in Tax: Audits, Litigation & Collection, International Taxation

The IRS has started 2013 with a win by obtaining a guilty plea from Wegelin for conspiring with U.S. taxpayers and others to hide more than $1.2 billion in secret Swiss bank accounts. Further, the monetary fines imposed total more than $74 million. No banking institution is too great to...

DISTRICT COURT DECIDES FBAR PENALTY ASSESSMENT CASE – BOTH A WIN FOR THE GOVERNMENT & FOR OVDP PARTICIPANTS

Posted on November 21, 2012February 19, 2019 by Moskowitz LLP Posted in International Taxation

Here at Moskowitz LLP, A Tax Law Firm based in San Francisco, CA, we have been following just how the Internal Revenue Service will collect FBAR penalties once imposed outside the scope of any Offshore Amnesty Program. In its decision November 8, 2012, the District Court for the District of...

South Korean government cracks down on offshore accounts

Posted on October 30, 2012February 19, 2019 by Moskowitz LLP Posted in International Taxation

In the last 10 years, South Korea has seen an incredible surge in economic expansion. The country now represents the fourth largest economy in Asia, and the capital city of Seoul - particularly its Gangnam neighborhood - has become a capitalist paradise teeming with big-name brands and luxury boutiques. However,...

Offshore Amnesty Penalties: An Unfortunate Driving Force for Renouncing Citizenship

Posted on September 24, 2012February 19, 2019 by Moskowitz LLP Posted in International Taxation

Moskowitz LLP, A Tax Law Firm, regularly counsels individuals with foreign connections on U.S. taxation issues, facing offshore amnesty penalties. Here in San Francisco and the Silicon Valley, in particular, and California in general, we have recently seen an increase in individuals considering renouncing their U.S. citizenship1 and green cards...

Just how is the Expatriation Tax Calculated?

Posted on September 11, 2012April 1, 2022 by Moskowitz LLP Posted in International Taxation

Introduction It has been all over the news lately, wealthy U.S. taxpayers, such as, Eduardo Saverin (a Facebook founder), Denise Rich (songwriter), and another eighteen hundred, or so, have forfeited their U.S. citizenship for U.S. tax reasons. Federal law provides that some U.S. taxpayers who elect to renounce their U.S....

U.S. Tax Effects of Treaties in the Context of Foreign Investment in the U.S.

Posted on September 6, 2012February 19, 2019 by Moskowitz LLP Posted in International Taxation, Real Estate Law

Introduction Foreign investors in the U.S. tend to have the same goals as their U.S. counterparts. Like U.S. taxpayers, foreign investors seek to minimize their income tax liabilities associated with their U.S. real estate and business investments. However, foreign investor’s objectives are clouded by the fact that they are not...

Piercing Asia – U.S. Offshore Bank Account Crackdown results in data on undeclared bank accounts with Hong Kong Connections

Posted on August 24, 2012February 19, 2019 by Moskowitz LLP Posted in International Taxation

On August 20, 2012, the United States Attorneys Office issued a press release regarding their most recent Offshore Bank Account Plea Agreement reached. The taxpayer, Jacquez Wajsfelner pled guilty to willfully failing to file foreign bank account reports (FBAR) for several Swiss Bank Accounts. Slightly outside the average age of...

Non-Citizens Risk Immigration Status for Offshore Bank Accounts

Posted on August 22, 2012February 19, 2019 by Moskowitz LLP Posted in International Taxation

The increased focus by the IRS on foreign income has generated a lot of news and a slew of criminal prosecutions. While US citizens need to consider the possibility of monetary penalties or a long prison sentence, resident non-citizens (green card holders) also need to worry about the possibility of...

United States and South Korea Coordinate to Combat Monetary & Tax Crimes

Posted on August 2, 2012February 19, 2019 by Moskowitz LLP Posted in International Taxation

To combat money and tax crimes, such as tax evasion and money laundering, the United States and Korean Governments have committed to a simultaneous criminal investigation program, SCIP. The arrangement allows the respective tax departments; the United States’ Internal Revenue Service (IRS) and South Korea’s National Tax Service (NTS), to...

FBAR Filing Deadline – Receipt on or before June 30

Posted on June 26, 2012February 19, 2019 by Moskowitz LLP Posted in International Taxation, Tax Planning & Compliance

Foreign Bank Account Report, Treasury Department Form 90-22.1 (FBAR) Who Must File an FBAR: Generally, every U.S. person with a financial interest in or signature or other authority over, any financial account outside of the United States, must file an FBAR if the aggregate value of all accounts exceeds $10,000...

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Category: International Taxation