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

Innocent Spouse, Expansion of Program

Posted on August 13, 2013February 19, 2019 by Moskowitz LLP Tax Planning & Compliance,

The U.S. Internal Revenue Service has proposed rules to extend the amount of time taxpayers can apply for its "innocent spouse" relief program which stops collection of taxes in certain situations. The Innocent Spouse program is a safety net for as many as 50,000 taxpayers per year who have filed...

Offshore Initiative – Another NPA reached: DOJ 23.8 million settlement with Liechtensteinische Landesbank AG (LLB-Vaduz)

Posted on August 1, 2013February 19, 2019 by Moskowitz LLP Criminal Tax Law, International Taxation,

On July 29, the United States Justice Department (DOJ) announced in a press release that it had reached a $23.8 million settlement with Liechtensteinische Landesbank AG (LLB-Vaduz), halting its criminal investigation of the bank in aiding US citizen's in evading their U.S. tax obligations. As part of the investigation, the...

Santa Clara County man pleads guilty to hiding Israeli bank account

Posted on July 29, 2013February 19, 2019 by Moskowitz LLP Criminal Tax Law, International Taxation,

On July 17, the U.S. Justice Department announced in a press release that Moshe Handelsman of Saratoga, California, plead guilty to tax perjury. This case is the latest in a series involving un-reported foreign bank accounts and Israeli banks under scrutiny by the Justice Department and Internal Revenue Service (IRS)...

Alameda County, California

Posted on July 25, 2013February 19, 2019 by Moskowitz LLP State & Local Taxation, Business Law, Tax Planning & Compliance,

The experienced tax attorneys at Moskowitz LLP are available to help the taxpayers and businesses of Alameda County. A few of the ways in which we can assist the unique needs of the county are listed below: Agriculture Farming in California generates over $30 billion a year and Alameda County...

FATCA withholding delayed for six months

Posted on July 12, 2013February 19, 2019 by Moskowitz LLP International Taxation,

On July 12, the U.S. Treasury Department and the Internal Revenue Service (IRS) announced that the implementation of the Foreign Account Tax Compliance Act (FATCA) would be postponed for six months to allow foreign entities to finalize their intergovernmental agreements with the IRS. As such, FATCA withholding by foreign institutions...

U.S. Government to Use the Treasury Department to Identify Individuals Owning Foreign Assets

Posted on June 18, 2013April 1, 2022 by Moskowitz LLP International Taxation, Tax Planning & Compliance, Tax: Audits, Litigation & Collection,

At the G8 meeting in Ireland, the White House announced it's intent to facilitate international tax and business arrangement transparency by promising a plan to assist law enforcement and tax authorities in identifying those who own and control entities outside of the United States. We have been reporting on the...

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...

Understanding how Apple Pays No Income Tax

Posted on June 5, 2013February 19, 2019 by Moskowitz LLP Tax Planning & Compliance,

Our short article describing the tax plan that Apple (and many other smaller companies) can utilize to legally minimize their rate to pay no income tax can be found here. When Apple Inc. disclosed that it has not paid any corporate income tax over the past 4 years, it got...

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...

Residency Under U.S. Tax Law

Posted on June 2, 2013February 19, 2019 by Moskowitz LLP International Taxation, Tax Planning & Compliance,

Taxation of non-U.S. citizens is determined based on the residency status of the individual or entity. Different from U.S. immigration laws, the tax laws divide taxpayer into two categories: Resident aliens are taxed in the same manner as U.S. citizens on their worldwide income, and Nonresident aliens are taxed according...

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...

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