Why a Tax Attorney’s Advice is Important: Case Study – Cavallaro

Posted on by Moskowitz LLP Posted in Estate Planning & Taxation, Tax Planning & Compliance, Tax: Audits, Litigation & Collection
Estate Planning, Gift Tax, Business Succession, and the Ability to Rely on Advice of Counsel JD Supra Business Advisor recently published our case study on the Tax Court Opinion in the Cavallaro matters - a true rags to riches story involving taxation, and why a tax attorney's advice/representation is important....
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Appeals Judicial Approach and Culture (AJAC) Project, Part II

Posted on by Moskowitz LLP Posted in Tax Planning & Compliance, Tax: Audits, Litigation & Collection
Collection Due Process and Offers in Compromise In Part I of this series, we introduced the Appeals Judicial Approach and Culture (AJAC) Project and new guidelines for tax appeals. We also discussed the importance of having an independent IRS appeals process and noted that with limited exceptions, the government is...
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The Multilateral Convention on Mutual Administrative Assistance in Tax Matters, Part III

Posted on by Moskowitz LLP Posted in Criminal Tax Law, Tax: Audits, Litigation & Collection
Other Posts in this Series Part I Part II Part IV A discussion of tax matter cooperation isn't complete without addressing the coordination of audits.  In this third part of our series discussing the international effort to combat tax avoidance and evasion through the Multinational Convention on Mutual Administrative Assistance...
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The Multilateral Convention on Mutual Administrative Assistance in Tax Matters, Part IV

Posted on by Moskowitz LLP Posted in Criminal Tax Law, Tax: Audits, Litigation & Collection
Other Posts in this Series Part I Part II Part III The first three segments in this series on the Multinational Convention on Mutual Administrative Assistance in Tax Matters (the "Convention") focus on the abilities states party to the Convention enjoy.  This includes the ability to exchange information and cooperate...
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The Multilateral Convention on Mutual Administrative Assistance in Tax Matters, Part II

Posted on by Moskowitz LLP Posted in Criminal Tax Law, Tax: Audits, Litigation & Collection
Other Posts in this Series Part I Part III Part IV In Part I of this series, we provided an introduction to the Multilateral Convention on Mutual Administrative Assistance in Tax Matters (the "Convention") and described two methods of information exchange promoted by the Convention.  In Part II, we discuss...
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The Multilateral Convention on Mutual Administrative Assistance in Tax Matters, Part I

Posted on by Moskowitz LLP Posted in Criminal Tax Law, Tax: Audits, Litigation & Collection
Other Posts in this Series Part II Part III Part IV Countries have long recognized that, while tax administrations are confined to their respective jurisdictions, taxpayers function on a global level. In 1988, the Organization for Economic Cooperation (OECD) and the Council of Europe established the Multinational Convention on Mutual...
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Your Frequent Flyer Miles May Be Taxable Income

Posted on by Moskowitz LLP Posted in Tax Planning & Compliance, State & Local Taxation, Tax: Audits, Litigation & Collection
For many years, banks have provided incentives to open a new bank account-30 years ago they handed out silverware and toasters, now they offer cash and frequent flyer miles. The IRS has for the most part ignored these incentives, but Citibank's overzealous interpretation of the tax code may have just...
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