The Qualified Quiet Disclosure: Operating Outside of the IRS Offshore Voluntary Disclosure Initiative

Posted on by Moskowitz LLP Posted in Tax: Audits, Litigation & Collection
Individuals with previously undisclosed foreign assets and/or income have a variety of options to become compliant with the IRS, with two avenues for resolution being the most common: Qualified Quiet Disclosure and the Offshore Voluntary Disclosure Program ("OVDP"). Absent facts indicating willful or reckless intent, an individual may be better...
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IRS Targets: Tax Audits of Partnerships, LLCs, and other Pass-through Entities

Posted on by Moskowitz LLP Posted in Business Law, Tax: Audits, Litigation & Collection
The Internal Revenue Service announced on November 7, 2013, that it intends to make auditing and examining partnership and other pass-through entities, such as LLCs, S-Corporations, and sole proprietorships a top priority in 2014.  This comes after years of targeting corporations for exam. Pass-Through Entity returns are subject to the...
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Tax Case of the Week: Trust Fund Recovery Penalty for a Responsible Person

Posted on by Moskowitz LLP Posted in Tax: Audits, Litigation & Collection, Criminal Tax Law
This week, the Court of Appeals for the 4th Circuit decided a case regarding whether the trust fund recovery penalties were properly imposed against an individual, who was an officer of the corporation that failed to pay over payroll tax, but was not involved with day to day operations, and...
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FTB Collections Gone Wrong

Posted on by Moskowitz LLP Posted in Tax: Audits, Litigation & Collection, State & Local Taxation
On this blog we often report about individuals who were caught avoiding paying their taxes and punished. Sometimes, however, the Internal Revenue Service (IRS) and the Franchise Tax Board (FTB) get it completely wrong. For instance, recently a Nevada-resident woman, age 65, received notices from the Franchise Tax Board stating...
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Report: IRS needs to increase prior- and subsequent-year tax return audits

Posted on by Moskowitz LLP Posted in Tax: Audits, Litigation & Collection
According to a report by the Treasury Inspector General for Tax Administration (TIGTA), The Internal Revenue Service (IRS) needs to develop and implement more ways to determine which tax returns should be audited. The report recommends that the tax-collecting agency audit more of the prior- and subsequent-year tax returns of...
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San Francisco man admits hiding foreign bank account

Posted on by Moskowitz LLP Posted in International Taxation, Tax: Audits, Litigation & Collection
If you hold assets in a foreign bank account, you are required by law to report these funds to the Internal Revenue Service (IRS). Although many taxpayers have hidden foreign accounts from the government in the past, the government through its Offshore Initiative has drastically increased the identification of those...
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U.S. Government to Use the Treasury Department to Identify Individuals Owning Foreign Assets

Posted on by Moskowitz LLP Posted in International Taxation, Tax Planning & Compliance, Tax: Audits, Litigation & Collection
At the G8 meeting in Ireland, the White House announced it's intent to facilitate international tax and business arrangement transparency by promising a plan to assist law enforcement and tax authorities in identifying those who own and control entities outside of the United States. We have been reporting on the...
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Math Errors on Tax Returns

Posted on by Moskowitz LLP Posted in Tax: Audits, Litigation & Collection, Tax Planning & Compliance
Despite the fact that a growing number of U.S. taxpayers are submitting their tax returns electronically - a method that, in theory, should promote accuracy by automatically tallying totals - The Associated Press recently revealed that mathematical errors may be on the rise.   The A.P. reports that 2.7 million miscalculations...
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