Tax Audit Law Posts from the Tax Lawyer Blog at Moskowitz LLP

Crackdown on Israeli Banks and U.S. Expats

Posted on October 24, 2018February 25, 2019 by Moskowitz LLP Posted in Tax: Audits, Litigation & Collection, International Taxation

Israeli banks are being investigated by the U.S. government, and American expats are feeling the heat. The year 2007 marked the beginning of a major shift in world banking. It began with the UBS scandal and the dismantling of Swiss bank secrecy laws, and continued with the enactment of FATCA...

First Steps to Establishing Your New Business: Know Your Business Taxes!

Posted on October 2, 2018February 13, 2019 by Moskowitz LLP Posted in Business Law, State & Local Taxation, Tax Planning & Compliance, Tax: Audits, Litigation & Collection

Other Posts in this Series Choosing the Right Business Structure for You, Part I Choosing the Right Business Structure for You, Part II The Initial Paperwork Other Filings, Other States Management and Risk Your company is responsible for various types of business taxes, and if you don’t comply you could...

IRS Blocks SALT Cap Workarounds

Posted on September 19, 2018February 13, 2019 by Moskowitz LLP Posted in Tax Planning & Compliance, State & Local Taxation, Tax: Audits, Litigation & Collection

Attempts to Circumvent $10,000 SALT Cap Blocked The U.S. Treasury Department recently issued a new regulation stating that taxpayers cannot claim that they made a charitable contribution if they received a state tax credit in exchange for a “gift” to a state fund. This rule effectively blocks state proposals aimed...

A Few Words on President Trump’s New Supreme Court Pick

Posted on September 12, 2018February 13, 2019 by Moskowitz LLP Posted in Tax: Audits, Litigation & Collection, Tax Planning & Compliance

Immediately following Justice Kennedy’s July 31, 2018 announcement of his retirement, Brett Kavanaugh, a prominent conservative D.C. Circuit Court judge, received a call from the President. This marks Donald Trump’s second opportunity to appoint a Supreme Court Justice. Since his nomination on July 9, 2018, Kavanaugh has been the subject...

Taxpayer Win: Failure to File Accurate FBAR Deemed Not Willful, Part IV

Posted on July 26, 2018February 13, 2019 by Moskowitz LLP Posted in Business Law, Tax Planning & Compliance, Tax: Audits, Litigation & Collection

Other Posts in this Series Part I Part II Part III The story of Arthur Bedrosian, CEO of Lannett Company, Inc., and his Swiss bank accounts shows how a taxpayer’s cooperation with an IRS investigation and the court’s belief in the taxpayer’s honesty can be significant factors in the outcome...

Taxpayer Win: Failure to File Accurate FBAR Deemed Not Willful, Part III

Posted on July 24, 2018February 13, 2019 by Moskowitz LLP Posted in Tax: Audits, Litigation & Collection, Business Law, Tax Planning & Compliance

Other Posts in this Series Part I Part II Part IV Before the Offshore Voluntary Disclosure Program (OVDP), it was rare for a taxpayer to pay penalties when they voluntarily came forward with information regarding their foreign accounts. Most tax practitioners, therefore, recommended that their clients do a “quiet” disclosure,...

Taxpayer Win: Failure to File Accurate FBAR Deemed Not Willful, Part II

Posted on July 19, 2018February 13, 2019 by Moskowitz LLP Posted in Tax: Audits, Litigation & Collection, Business Law, Tax Planning & Compliance

Other Posts in this Series Part I Part III Part IV In Part I, we described the background of Bedrosian v. United States, 3d Cir., No. 17-3525, in which the CEO of a pharmaceutical company was pursued for willful FBAR penalties. The IRS didn’t go after Arthur Bedrosian for his...

Meet Our Newest Attorney

Posted on July 17, 2018October 12, 2020 by Moskowitz LLP Posted in Tax Planning & Compliance, Tax: Audits, Litigation & Collection

We are pleased to announce the addition of Tyson Smith as Associate Attorney with Moskowitz LLP. We are honored to welcome Tyson to the team at Moskowitz LLP, and fully expect that he will continue to use the experience, skill and work ethic he has demonstrated since joining our firm to...

Taxpayer Win: Failure to File Accurate FBAR Deemed Not Willful, Part I

Posted on July 13, 2018February 13, 2019 by Moskowitz LLP Posted in Tax Planning & Compliance, Business Law, Tax: Audits, Litigation & Collection

Other Posts in this Series Part II Part III Part IV The IRS aggressively pursues taxpayers for FBAR noncompliance, but in this case it may have overreached its boundaries. CEO takes bad advice Arthur Bedrosian is currently Chief Executive Officer of Lannett Company, Inc., a manufacturer and distributor of generic...

Government Regulation of Cryptocurrency

Posted on June 15, 2018February 13, 2019 by Moskowitz LLP Posted in Tax: Audits, Litigation & Collection, Cryptocurrency Tax Assistance

Governments throughout the world have begun developing regulations for cryptocurrency exchanges. In this post, we will provide an overview of how various U.S. government agencies view cryptocurrencies and what they are doing to prevent their misuse. The Internal Revenue Service Digital currency = property In 2014, the IRS issued Notice...

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Category: Tax: Audits, Litigation & Collection