The Tax Lawyer Blog: Topical thinking from the lawyers at Moskowitz, LLP

Foreign Tax Credit: What is it?

Posted on March 22, 2022March 22, 2022 by Erin Humbles International Taxation,

An Overview of the Foreign Tax Credit The foreign tax credit is exactly what it states in the title. It is a credit for the foreign taxes paid in another country. However, a taxpayer must qualify for the credit. Under 26 U.S.C. 901, a taxpayer may choose to be credited...

The Aftermath of IRS Offshore Voluntary Disclosure Program- Foreign Bank Accounts

Posted on January 12, 2022February 1, 2022 by Erin Humbles International Taxation,

You made an Offshore Voluntary Disclosure, now what? In July 2019, the Internal Revenue Service (“IRS”) Large Business and International Division announced the next steps after taxpayers made a voluntary disclosure regarding unreported bank accounts or foreign assets. When taxpayers make a voluntary disclosure, each taxpayer essentially promises to stay...

What to Do if You Have an Unreported Foreign Bank Account

Posted on April 6, 2020April 7, 2020 by Erin Humbles International Taxation, Tax: Audits, Litigation & Collection,

The Tax Law Firm of Moskowitz, LLP represents individuals and businesses that have not reported their foreign bank accounts or income. Since the IRS cracked UBS in 2008, the agency has been on a crusade to end the practice of hiding offshore income and bank accounts valued at more than...

International Information Returns

Posted on January 16, 2020February 28, 2020 by Erin Humbles International Taxation, Tax Planning & Compliance,

There are extraordinarily high tax penalties for the late filing of certain international information returns. If you have assets overseas, you most likely have at least one international information return reporting requirement. Don’t ignore these filings or you could lose a large portion of your investment to tax penalties. Do...

International Issues in Estate Planning: One Will or Two?

Posted on January 10, 2020November 25, 2020 by Erin Humbles Estate Planning & Taxation, International Taxation,

You may need to have a separate will for each country in which you have assets. Individuals and couples with assets in more than one country need to ensure that their estate planning documents are valid in all the jurisdictions in which they have property. Although in some instances this...

For a Limited Time Only, Moskowitz is Offering Year-End Tax Planning Services

Posted on November 26, 2019December 15, 2020 by Erin Humbles Estate Planning & Taxation, International Taxation, State & Local Taxation, Tax Planning & Compliance, Tax Services,

Think the Trump Tax Cuts and Jobs Act of 2017 doesn’t matter to you? Your ignorance could be costing you lots of money. Schedule a meeting now to see if our year end planning services can reduce your 2019 tax bill. Schedule with Cliff Now Moskowitz attorneys and accountants have...

Captive Insurance Companies, Part IV: Crackdown on Captive Insurance Abuses

Posted on September 24, 2019January 7, 2020 by Erin Humbles Business Law, Estate Planning & Taxation, International Taxation, Tax Planning & Compliance,

Previous Posts in this Series Part I: What is a Captive Insurance Company? Part II: Types of Captives Part III: Benefits and Risks A captive insurance company manages its parent company’s business risks while providing it with substantial benefits. However, abuse of the tax benefits of captives – particularly small...

Captive Insurance Companies, Part III: Benefits and Risks

Posted on September 19, 2019January 7, 2020 by Erin Humbles Business Law, Estate Planning & Taxation, International Taxation, Tax Planning & Compliance,

Previous Posts in this Series Part I: What is a Captive Insurance Company? Part II: Types of Captives Captive insurance companies provide businesses with savings opportunities, tax benefits, and greater flexibility in managing insurance needs. However, they are subject to pricing fluctuations, require significant capital, and pose some administrative challenges,...

Dual Status Aliens – Part II: Tax Deductions, Exemptions and Credits

Posted on September 3, 2019October 13, 2020 by Erin Humbles International Taxation, Tax Planning & Compliance,

Dual Status Aliens are entitled to certain tax deductions, exemptions, and credits. As we noted in Part I, if you are a Dual Status Alien, you must pay taxes on your worldwide income for the part of the year that you are a resident alien and on your U.S. income...

Dual Status Aliens – Part I: Residency

Posted on August 29, 2019January 7, 2020 by Erin Humbles International Taxation, Tax Planning & Compliance,

For U.S. taxpayers arriving or departing the country, your tax status can have a significant impact on your year-end tax bill. The U.S. is notorious for being one of the only countries in the world that taxes its citizens and permanent residents on their worldwide income. If you are a...

What Constitutes “Willful” Failure to File An FBAR?

Posted on July 2, 2019January 26, 2021 by Erin Humbles International Taxation, Tax: Audits, Litigation & Collection,

The willful failure to file an FBAR results in higher tax penalties than the non-willful failure to do so. But how does the IRS determine that your failure to act was “willful”? The U.S. Government’s stringent foreign bank account reporting requirements are accompanied by horribly disproportionate penalties for failure to...

Keeping a Piece of You: Taxation of U.S. Citizens Living Abroad

Posted on June 20, 2019June 11, 2019 by Erin Humbles International Taxation, Tax Planning & Compliance,

U.S. tax laws are relatively unique in that they require all U.S. citizens and resident aliens to file U.S. tax returns and pay U.S. taxes even if they are living abroad. In addition, even if they produce no interest, foreign accounts totaling $10,000 at any time during the year must...

Failure to Report Foreign Account Results in Fine of 50% of Account Balance

Posted on May 7, 2019October 13, 2020 by Erin Humbles International Taxation, Tax Planning & Compliance,

Taxpayer liable for maximum willful FBAR penalty of 50% of account balance for failing to report foreign assets. The willful FBAR penalty battle rages on. The recent holding in Kimble vs. United States is a tremendous setback to taxpayers who have been delinquent with their foreign account reporting. Here is...

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