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

IRS to Target Virtual Currencies for Tax and BSA Violations

Posted on June 13, 2013February 19, 2019 by Moskowitz LLP Tax: Audits, Litigation & Collection,

Already in the midst of cracking down on offshore tax and banking violations as part of its war on global tax evasion, the Internal Revenue Service (IRS) has recently revealed that it sees the rise of virtual currencies as an avenue for tax evasion and money laundering schemes. "Clearly the...

Joseph Bray: Giving clients a voice

Posted on June 5, 2013February 19, 2019 by Moskowitz LLP Criminal Tax Law, Real Estate Law, Tax: Audits, Litigation & Collection,

Born and raised in San Francisco by an East Coast conservative father and West Coast liberal mother, Joseph Bray grew up in a divided household, one where heated political and legal debates were commonplace at the dinner table. By the time Bray was a high school sophomore, years of robust...

Math Errors on Tax Returns

Posted on June 4, 2013February 19, 2019 by Moskowitz LLP 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...

A Q&A with Joseph Bray, associate tax attorney at Moskowitz LLP

Posted on May 29, 2013February 19, 2019 by Moskowitz LLP Tax: Audits, Litigation & Collection,

Joseph M. Bray is an associate tax attorney at Moskowitz LLP, providing insight and experience to cases concerning corporate and personal tax disputes. Read this Question and Answer session to learn more about Bray's approach to tax law and his experience with the firm. How do you add to the...

Restaurant Owner Audited – Triggered by Tip Report

Posted on May 22, 2013February 19, 2019 by Moskowitz LLP Business Law, Tax: Audits, Litigation & Collection,

Because restaurants deal in cash and tips, the Internal Revenue Service (IRS) has devised systems to enforce tax compliance by requiring employers bear the ultimate burden for Federal Insurance Contribution Act (FICA) taxes owed by employees under reporting the tips they receive. It does this by requiring restaurant to file...

What a Tax Attorney Can Do for You: Understand How Apple, Inc. Legally Does Not Pay Income Tax

Posted on May 21, 2013February 19, 2019 by Moskowitz LLP Tax: Audits, Litigation & Collection,

When Apple Inc., disclosed that it has not paid any corporate income tax over the past 4 years, it got the government’s attention. Hailed before the Senate, Apple is confident in their tax position because it is legal. Essentially, Apple games the system by aggressively manipulating the Internal Revenue Code...

IRS to target “quiet” offshore tax disclosures in light of new report

Posted on May 1, 2013February 19, 2019 by Moskowitz LLP Tax: Audits, Litigation & Collection, International Taxation,

Given the aggressive public overtures that Internal Revenue Service (IRS) officials have made regarding offshore bank accounts and tax evasion in the last five years, many taxpayers took advantage of the Offshore Voluntary Disclosure Program offered by the Internal Revenue Service. However, a report issued by the GAO (Government Accounting...

Collection Due Process Hearings: Is it A Second Chance for Taxpayers to Litigate a Matter Previously Missed?

Posted on March 28, 2013April 1, 2022 by Moskowitz LLP Tax: Audits, Litigation & Collection,

Introduction It happens all the time. Taxpayers are assessed tax liabilities by the Internal Revenue Service (IRS). To make matters worse for many taxpayers, they fail to timely petition the United States Court to contest the assessment. In many cases, had such a taxpayer timely petitioned the United States Tax...

Tax scams to watch out for this season: Part 1

Posted on March 27, 2013February 19, 2019 by Moskowitz LLP Tax: Audits, Litigation & Collection,

If you have yet to file your tax return for the 2012 fiscal year, you still have time to enlist the aid of a tax professional. Recently, the Internal Revenue Service (IRS) issued a press release regarding some of the most common tactics that unscrupulous individuals may use to take...

IRS Continues Offshore Bank Account Crackdown in 2013

Posted on January 10, 2013February 19, 2019 by Moskowitz LLP Tax: Audits, Litigation & Collection, International Taxation,

The IRS has started 2013 with a win by obtaining a guilty plea from Wegelin for conspiring with U.S. taxpayers and others to hide more than $1.2 billion in secret Swiss bank accounts. Further, the monetary fines imposed total more than $74 million. No banking institution is too great to...

Donating to Charity may be a tax benefit but it also is a Red Flag for an IRS Audit

Posted on December 29, 2012February 19, 2019 by Moskowitz LLP Tax: Audits, Litigation & Collection,

Giving to others is rewarding in and of itself, but it's always nice to see your generosity provide you with a tax benefit and result in a lower tax bill. In our tax law practice we represent many individuals and one of the most often audited items on tax returns...

Modern Day Witch Hunt: IRS Making Examples of Celebrities

Posted on December 29, 2012October 13, 2020 by Moskowitz LLP Business Law, Tax: Audits, Litigation & Collection,

How the IRS and State Taxing Authorities Purposefully Target and Make Examples out of Celebrities The Supreme Court of the United States has held that the pursuit of tax crime is "calculated to induce prompt and forthright fulfillment of every duty under the income tax law." Spies v. United States,...

IRS and FTB file tax liens against Baywatch beauty

Posted on December 18, 2012February 19, 2019 by Moskowitz LLP Criminal Tax Law, Tax: Audits, Litigation & Collection,

Unlike most Americans, whose sources of income are fairly consistent, celebrities' earnings - though more substantial - tend to be a bit erratic. For instance, while the stars of a weekly sitcom can expect a regular paycheck, what about the famous faces that sign a movie contract every year or...

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