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

What to Do If You Have an Unreported Foreign Bank Account

Posted on April 6, 2020April 7, 2020 by moskowitz 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...

An Faq for Surviving the Financial and Tax Implications of Covid -19

Posted on March 30, 2020April 8, 2020 by moskowitz Distressed Business/COVID-19, Estate Planning & Taxation, State & Local Taxation, Tax Planning & Compliance, Tax Services, Tax: Audits, Litigation & Collection,

As our country and clients continue to struggle with the changing landscape created by the COVID-19 epidemic, Moskowitz LLP will continue to keep our clients apprised of changes imposed on tax and financial planning by the virus. Below, we've put together an FAQ of questions and answers which our clients...

Preparing for a California Residency Audit (archived)

Posted on November 7, 2019December 6, 2021 by moskowitz State & Local Taxation, Tax: Audits, Litigation & Collection,

California taxing authorities aggressively pursue state revenue through taxation, and devote a significant amount of their resources to residency audits and litigation. Gilbert Hyatt made history and $90 million when he invented the integrated circuit microprocessor (the computer microchip). Little did he know at the time that he would also...

What Constitutes “willful” Failure to File an Fbar?

Posted on July 2, 2019January 26, 2021 by moskowitz 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...

Compromising with the Irs – Easier, but Still Not an Easy Out

Posted on June 18, 2019June 11, 2019 by moskowitz Tax Planning & Compliance, Tax: Audits, Litigation & Collection,

If you can’t pay your full tax liability, an Offer in Compromise (OIC) may be an option to settle your tax debt for less than the full amount owed. Note, however, most OICs are not approved by the IRS, and even when accepted they may still pose a challenge to...

Contesting Tax Penalties: Abatement

Posted on June 4, 2019May 21, 2019 by moskowitz Tax: Audits, Litigation & Collection,

In our last post, we discussed a few of the most common tax penalties imposed by the IRS. Here we explain some ways of getting those penalties, and interest, reduced or removed entirely (otherwise known as “abatement”). It’s bad enough owing taxes, but when penalties and interest are added your...

An Introduction to Tax Penalties

Posted on May 30, 2019May 21, 2019 by moskowitz Tax: Audits, Litigation & Collection,

There are numerous tax penalties that the IRS imposes for tax code violations. Here is a brief summary of the four most common ones. When you receive an IRS tax bill, it is usually accompanied by interest and penalties, which may be significant. The next few posts will describe when...

Crackdown on Israeli Banks and U.s. Expats

Posted on October 24, 2018February 25, 2019 by moskowitz 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...

First Steps to Establishing Your New Business: Know Your Business Taxes!

Posted on October 2, 2018February 13, 2019 by moskowitz Business Law, State & Local Taxation, Tax Planning & Compliance, Tax: Audits, Litigation & Collection,

Other Posts in this Series Choosing the Right Business Structure for You, Part I Choosing the Right Business Structure for You, Part II The Initial Paperwork Other Filings, Other States Management and Risk Your company is responsible for various types of business taxes, and if you don’t comply you could...

Irs Blocks Salt Cap Workarounds

Posted on September 19, 2018February 13, 2019 by moskowitz Tax Planning & Compliance, State & Local Taxation, Tax: Audits, Litigation & Collection,

Attempts to Circumvent $10,000 SALT Cap Blocked The U.S. Treasury Department recently issued a new regulation stating that taxpayers cannot claim that they made a charitable contribution if they received a state tax credit in exchange for a “gift” to a state fund. This rule effectively blocks state proposals aimed...

A Few Words on President Trump’s New Supreme Court Pick

Posted on September 12, 2018February 13, 2019 by moskowitz Tax: Audits, Litigation & Collection, Tax Planning & Compliance,

Immediately following Justice Kennedy’s July 31, 2018 announcement of his retirement, Brett Kavanaugh, a prominent conservative D.C. Circuit Court judge, received a call from the President. This marks Donald Trump’s second opportunity to appoint a Supreme Court Justice. Since his nomination on July 9, 2018, Kavanaugh has been the subject...

Taxpayer Win: Failure to File Accurate Fbar Deemed Not Willful, Part Iv

Posted on July 26, 2018February 13, 2019 by moskowitz 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 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,...

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