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

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

Posted on June 20, 2019June 11, 2019 by Moskowitz LLP 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 Moskowitz LLP 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...

Crackdown on Israeli Banks and U.S. Expats

Posted on October 24, 2018February 25, 2019 by Moskowitz LLP Tax: Audits, Litigation & Collection, International Taxation,

Israeli banks are being investigated by the U.S. government, and American expats are feeling the heat. The year 2007 marked the beginning of a major shift in world banking. It began with the UBS scandal and the dismantling of Swiss bank secrecy laws, and continued with the enactment of FATCA...

New Global Partnership Formed to Combat International Tax Crime

Posted on October 15, 2018February 13, 2019 by Moskowitz LLP International Taxation, Criminal Tax Law, Cryptocurrency Tax Assistance,

Law enforcement leaders from five countries have joined efforts in their fight against international tax crime and money laundering. The new “Joint Chiefs of Global Tax Enforcement” (J5) brings together tax enforcement authorities from Australia, Canada, the Netherlands, the U.K. and the U.S. to develop new strategies in the pursuit...

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...

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...

Foreign Account Reporting: Time Limit for IRS Action

Posted on March 9, 2018August 31, 2021 by Moskowitz LLP International Taxation, Tax Planning & Compliance, Tax: Audits, Litigation & Collection,

To conduct an audit or otherwise take action on a tax return, the IRS must generally act within three years from the later of either the return’s due date or the date it was filed. That time limit may be extended to six years if there has been a “substantial...

Update on IRS Offshore Initiatives: Investigations and agreements with financial institutions worldwide

Posted on January 18, 2018February 14, 2019 by Moskowitz LLP International Taxation, Tax Planning & Compliance, Tax: Audits, Litigation & Collection,

In our last post, we noted that the U.S. government goes to great lengths to identify and prosecute noncompliant taxpayers, as well as promoters and financial institutions who assist U.S. taxpayers avoid their tax obligations by hiding their offshore income and assets. Some recent plea agreements with large financial institutions...

Update on IRS Offshore Initiatives

Posted on January 16, 2018February 14, 2019 by Moskowitz LLP International Taxation, Tax Planning & Compliance, Tax: Audits, Litigation & Collection,

Global tax issues are a top priority for the Internal Revenue Service Criminal Investigation Division (IRS-CI), which focuses its work on investigating taxpayers who willfully engage in tax evasion. Significant efforts are also being made to identify and take legal action against promoters and financial institutions who have assisted taxpayers...

Undisclosed Foreign Accounts, Part II

Posted on November 6, 2017February 14, 2019 by Moskowitz LLP International Taxation,

This is a continuation of the first post on undisclosed foreign accounts. The executor of a decenent’s estate has a duty to act in a prudent manner and in accordance with the law. At times, this may result in having to take an unpopular position or action that angers the...

Undisclosed Foreign Accounts

Posted on November 3, 2017February 14, 2019 by Moskowitz LLP International Taxation,

Serving as Executor can at times be more of a headache than an honor. On top of a pile of paperwork and dealing with a multitude of family issues, you can be sued! Executors have a number of responsibilities, most importantly payment of the decedent’s outstanding tax liabilities, debts and...

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