The Qualified Quiet Disclosure: Operating Outside of the IRS Offshore Voluntary Disclosure Initiative

Posted on by Moskowitz LLP Tax: Audits, Litigation & Collection,
Individuals with previously undisclosed foreign assets and/or income have a variety of options to become compliant with the IRS, with two avenues for resolution being the most common: Qualified Quiet Disclosure and the Offshore Voluntary Disclosure Program ("OVDP"). Absent facts indicating willful or reckless intent, an individual may be better...
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IRS Targets: Tax Audits of Partnerships, LLCs, and other Pass-through Entities

Posted on by Moskowitz LLP Business Law, Tax: Audits, Litigation & Collection,
The Internal Revenue Service announced on November 7, 2013, that it intends to make auditing and examining partnership and other pass-through entities, such as LLCs, S-Corporations, and sole proprietorships a top priority in 2014.  This comes after years of targeting corporations for exam. Pass-Through Entity returns are subject to the...
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Report: IRS needs to increase prior- and subsequent-year tax return audits

Posted on by Moskowitz LLP Tax: Audits, Litigation & Collection,
According to a report by the Treasury Inspector General for Tax Administration (TIGTA), The Internal Revenue Service (IRS) needs to develop and implement more ways to determine which tax returns should be audited. The report recommends that the tax-collecting agency audit more of the prior- and subsequent-year tax returns of...
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San Francisco man admits hiding foreign bank account

Posted on by Moskowitz LLP International Taxation, Tax: Audits, Litigation & Collection,
If you hold assets in a foreign bank account, you are required by law to report these funds to the Internal Revenue Service (IRS). Although many taxpayers have hidden foreign accounts from the government in the past, the government through its Offshore Initiative has drastically increased the identification of those...
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