Cliff Capdevielle

Tax Attorney
Managing Attorney
415-394-7200 vCard contact
Cliff Capdevielle, Tax Attorney, Moskowitz LLP
Cliff Capdevielle, Tax Attorney, Moskowitz LLP

Education

  • University of San Diego School of Law, LL.M. in Taxation
  • University of San Diego School of Law, J.D.
  • University of California – Berkeley, B.A.

Bar Admissions

  • California

Court Admissions

  • U.S. Tax Court
  • U.S. District Court – Northern and Southern Districts of California

Practice Areas

  • Business Tax Planning and Compliance
  • Trust and Estate Planning
  • Tax Litigation
  • International Tax
  • Civil Litigation

Overview

Cliff’s unusual combination of skills has enabled him to develop sophisticated tax planning strategies and resolve tax disputes for clients more than two decades. As lawyer, accountant, longtime instructor and adjunct professor, he helps business and individual clients make sense of their circumstances and move forward with confidence.

With an advanced degree in taxation and extensive practical experience in tax planning, Cliff is relied on to formulate strategies to utilize the ever-changing array of federal and state tax laws – and relevant treaties – to clients’ benefit. This includes comprehensive counsel to businesses adapting to sweeping tax law changes enacted in 2017, and ongoing work with business owners and other individual taxpayers seeking to preserve assets through trust and estate planning.

In addition to his strong planning capabilities, Cliff has considerable experience representing businesses and individuals facing allegations of tax violations. He acts on behalf of clients in direct negotiation with the IRS and state tax authorities, and in litigation in U.S. Tax Court and other federal and state courts. He also represents clients under IRS and state audits and investigations.

Cliff’s clients have included corporations, small business owners, partnerships, and individual taxpayers. The foundations of his knowledge stem from early experience at Deloitte & Touche, one of the country’s largest accounting firms. He has since personally represented clients in tax matters and a range of civil litigation over the course of his career. Clients particularly appreciate Cliff’s ability to explain complex tax law in plain English, a skill he honed as an instructor and adjunct professor of accounting, tax and business law topics for 13 years.

Cliff has experience in a broad range of transactions involving U. S. persons and entities doing business overseas, and foreign individuals and businesses conducting business or acquiring property in the U.S. This work includes general international tax planning, subpart F income minimization, Check-the-Box planning, tax planning with foreign holding companies, tax treaty planning, as well as planning for the FIRPTA, the Foreign Investment in Real Property Tax Act.

Cliff represents U.S. taxpayers (residing in the U.S. and abroad) resolve or minimize their civil and criminal tax problems and assists clients who need to come into compliance with their U.S. tax obligations. Cliff has represented hundreds of clients in voluntary disclosures, FBAR Penalty exams, and civil and criminal tax investigations related to unreported foreign bank accounts.

At Moskowitz, and in the tax community, Cliff is looked to as a mentor for young attorneys and provides thoughtful counsel to colleagues when called upon.

Experience

Cliff’s experience in tax law and litigation includes the following:

  • Business tax planning and compliance
  • Trust and estate planning for individuals
  • Tax return preparation
  • Foreign asset reporting and compliance
  • Internal Revenue Service audits and investigations
  • United States Tax Court litigation
  • Federal district court litigation
  • California Franchise Tax Board disputes
  • California Employment Development Department disputes
  • Offers in compromise
  • Installment agreements
  • General international tax planning
  • Representation before IRS examinations and Appeals conferences
  • Representation before IRS Criminal Investigation Division
  • Representation before IRS offshore voluntary disclosure programs
  • Representation before IRS domestic voluntary disclosure programs
  • Criminal investigations and tax representation in criminal and civil matters
  • IRS CI and federal grand jury tax investigations
  • Bankruptcy Court tax litigation
  • General Bank Secrecy Act (BSA) compliance and regulations applicable to financial institutions
  • Know Your Customer (KYC) and Anti-money laundering (AML) laws, regulations and practice, including structuring AML policies
  • Money Service Business (MSB) compliance and Money Transmitter License (MTL) applications
  • Payments regulations as they relate to digital currency payments and mobile payments, CFTC, 1940 Act, and related compliance matters

Other Relevant Experience

  • Family law matters, child custody
  • Civil Litigation
  • Expert Witness

Faculty Member

  • Golden Gate University
    • International Tax
    • Partnership Tax
    • Trust & Estate Tax
  • UC Extension
    • Corporate Tax
    • Individual Tax

Awards & Affiliations

Member, California State Bar Association