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

The Colliot Case, Part II: $100,000 Limit on Civil FBAR Penalties

Posted on September 10, 2018February 13, 2019 by Moskowitz LLP International Taxation, Tax Planning & Compliance,

In Part I, we discussed a very significant case involving a taxpayer who willfully failed to file FBARs for a number of years. Mr. Dominique Colliot objected to the extraordinary penalties assessed against him, arguing that the federal regulation used by the IRS to justify its assessment had a $100,000...

$100,000 Limit on Civil FBAR Penalties: The Colliot Case, Part I

Posted on August 30, 2018February 13, 2019 by Moskowitz LLP International Taxation, Tax Planning & Compliance,

When people learn that their FBAR penalties have been set at 50% of their account balance for each year that they have been noncompliant, they get understandably upset. At a certain point, those penalties become absurd, particularly when little or no U.S. taxes were due on the foreign account in...

First Steps to Establishing Your New Business: Choosing the Right Business Structure for You, Part II

Posted on August 28, 2018February 13, 2019 by Moskowitz LLP Tax Planning & Compliance, Business Law,

Other Posts in this Series Choosing the Right Business Structure for You, Part I The Initial Paperwork Other Filings, Other States Know Your Business Taxes Management and Risk In Part I, we described four types of business structures: informally structured sole proprietorships and general partnerships, and two common corporate entities...

Paul Manafort Found Guilty

Posted on August 22, 2018February 13, 2019 by Moskowitz LLP Criminal Tax Law, International Taxation,

Paul Manafort has been found guilty of eight counts of filing false tax returns, failing to file FBARs, and bank fraud. The verdict is in. The jury has found Paul Manafort, President Trump’s former campaign manager, guilty of 8 of the 18 counts charged against him. Five counts of filing...

Paul Manafort on Trial: Round One

Posted on August 19, 2018February 13, 2019 by Moskowitz LLP Criminal Tax Law, International Taxation,

President Trump’s former campaign manager has been accused of hiding millions of dollars in foreign bank accounts, using international wires to fund a lavish lifestyle, and lying to banks to get loans for which he didn’t qualify. While we await the jury’s decision, here is a summary of the issues...

First Steps to Establishing Your New Business: Choosing the Right Business Structure for You, Part I

Posted on August 16, 2018February 13, 2019 by Moskowitz LLP Business Law, Tax Planning & Compliance,

Other Posts in this Series Choosing the Right Business Structure for You, Part II The Initial Paperwork Other Filings, Other States Know Your Business Taxes Management and Risk Turning your business idea into reality can be exciting and gratifying. Before you get started, however, you need to decide how your...

California’s Attempts to Circumvent the New Tax Law’s SALT Limitation

Posted on August 14, 2018February 13, 2019 by Moskowitz LLP State & Local Taxation, Tax Planning & Compliance,

Reports indicate that low-income and middle-class Californians are fleeing the state – most are relocating to Arizona, Nevada, and Texas. The reason? Housing costs and high taxes. The new tax law hasn’t necessarily helped wealthy California homeowners, either. For one thing, the Tax Cuts and Jobs Act (TCJA) capped their...

$125,000 State Tax Problem Fixed by Correcting Previous Years’ Tax Returns

Posted on August 8, 2018February 13, 2019 by Moskowitz LLP Business Law, State & Local Taxation, Tax Planning & Compliance,

A Moskowitz LLP Success Story A business owner came to us after receiving a Franchise Tax Board (FTB) Notice. The Notice stated that the FTB was disallowing a $1,204,541 million corporate loan to shareholder, and consequently assessed $125,197 in additional state income taxes. There is a long history of IRS...

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

Posted on July 26, 2018February 13, 2019 by Moskowitz LLP 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 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 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, 2018May 6, 2024 by Moskowitz LLP 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 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...

Tax Lawyer Blog

It starts with a conversation. Tell us about your needs.

It starts with a conversation.
Tell us about your needs.