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

Internal Revenue Code Section 7623: the Whistleblower Statute

Posted on November 23, 2010February 21, 2019 by moskowitz Criminal Tax Law, Business Law,

Under the Internal Revenue Code, individuals acting as “whistleblowers” by reporting underpayment of taxes or violation of tax laws by another taxpayer may be awarded money from the amount collected by the government. To be eligible for a section 7623 award, the disputed amount must exceed two million dollars, and...

Wesley Snipes to Serve Three Years in Federal Prison for Not Filing Tax Returns

Posted on November 19, 2010February 21, 2019 by moskowitz Tax Planning & Compliance, Criminal Tax Law, Tax: Audits, Litigation & Collection,

Owing taxes is not a crime, but his willfully not filing a tax return is San Francisco, CA - It is not a crime to owe money to the IRS. If Wesley Snipes had filed his tax returns but couldn't pay he would not be going prison. Willfully not filing is where...

Foreign Bank Accounts and the Voluntary Disclosure

Posted on November 3, 2010June 11, 2018 by moskowitz International Taxation, Criminal Tax Law,

Introduction For many years a large number of U.S. taxpayers have placed and may continue to place, money in foreign bank accounts. Many of these individuals, knowingly or unknowingly, violate federal law by not disclosing these foreign accounts on their federal income tax returns. In an effort to step-up enforcement...

Freeze & Seize Law – California

Posted on October 22, 2010June 11, 2018 by moskowitz State & Local Taxation, Criminal Tax Law,

Senior Partner, Law Offices of Stephen Moskowitz, LLP California Penal Code Section 186.11 is known as the 'Freeze and Seize Law.' This law allows a court to preserve a criminal defendant's assets in order to pay restitution to victims and any fines imposed for their misdeeds. Any money in bank...

Abusive Trust Schemes That the Internal Revenue Service Targets

Posted on June 6, 2010June 11, 2018 by moskowitz Tax Planning & Compliance, Criminal Tax Law,

Over the past decade, numerous individuals claiming to be knowledgeable tax advisors have promoted trust tax schemes. The promoters of these trust schemes often charge unsuspecting taxpayers $5,000 to $100,000 to establish intricate trust plans. Most of these promoters fully understand that they are marketing an illegal enterprise. However, in...

Swiss Government Approves Ubs-u.s. Tax Deal

Posted on June 1, 2010June 11, 2018 by moskowitz International Taxation, Criminal Tax Law,

Both house of the Swiss parliament have finally approved a tax treaty with the United States. The change in Swiss law means that Switzerland’s biggest bank, United Bank of Switzerland (UBS) will hand over to the United States Department of Justice the details of nearly 4,500 of their U.S. clients....

Offshore Bank Account Holders Missed Irs Offer That Expired October 15, 2009! Now What?

Posted on October 15, 2009January 26, 2021 by moskowitz Criminal Tax Law, International Taxation,

This blog is outdated, but our tax law firm is still helping taxpayers who have not reported their foreign income to avoid civil and criminal penalties. Learn more about our FBAR and foreign account reporting services or simply contact our California offices today. The IRS has steep penalties and even...

October 15, 2009 Deadline for Voluntary Disclosure

Posted on October 2, 2009June 11, 2018 by moskowitz International Taxation, Criminal Tax Law,

United States citizens who have an interest in, or signature or other authority over, a financial account in a foreign country with assets in excess of $10,000 are required to disclose the existence of such account on Schedule B, Part III of their individual income tax return. Additionally, U.S. citizens...

Is There Some Tax Relief Available for the Victims of Bernard Madoff?

Posted on January 6, 2009June 11, 2018 by moskowitz Criminal Tax Law, Business Law,

Date Published: Jan 2009 San Francisco Business Times Recently, it was discovered that Bernard Madoff was operating a Ponzi scheme that victimized numerous high profile investors. A Ponzi scheme is a fraudulent investment operation that pays returns from money received by subsequent investors rather than from any profits or earnings...

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