Taxation of Convertible Virtual Currency, Part III: Reporting and Penalties for Noncompliance

Posted on by Moskowitz LLP Posted in Criminal Tax Law, Tax: Audits, Litigation & Collection
Other Posts in this Series Part I: It’s Not Money Part II: Taxation of Virtual Currency Income When it comes to Bitcoins and other convertible virtual currency, anonymity may not be all it’s cracked up to be. For one thing, an underlying assumption is that individuals who keep their financial...
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IRS Appeals and the AJAC Project, Part I

Posted on by Moskowitz LLP Posted in Tax: Audits, Litigation & Collection, Tax Planning & Compliance
Maintaining an Independent IRS Appeals process In an effort to demonstrate to taxpayers that IRS Appeals can be done in a fair and impartial manner by an independent appeals process, the IRS introduced the Appeals Judicial Approach and Culture (AJAC) Project which promotes a quasi-judicial approach in the handling of...
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Crackdown on Tax Treaty Abuses

Posted on by Moskowitz LLP Posted in Tax: Audits, Litigation & Collection, Business Law, Tax Planning & Compliance
Tax authorities throughout the world are cracking down on taxpayers – individuals and corporations – that utilize some aggressive tax planning strategies. While most of these schemes are perfectly legal and merely take advantage of loopholes in the international tax system, there is a growing concern that they not only...
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Contesting an IRS Summons: The Impact of United States v. Clarke

Posted on by Moskowitz LLP Posted in Tax: Audits, Litigation & Collection, Criminal Tax Law
The Supreme Court recently issued a brief but significant ruling concerning a taxpayer's right to contest an IRS summons. Per 26 U.S.C. 7602, the IRS has a right to request information from a taxpayer through examination of books, papers, records, testimony, etc. pursuant to a civil or criminal IRS investigation....
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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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