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

Proposition 30 proposes higher income tax for well off in California

Posted on October 31, 2012February 19, 2019 by Moskowitz LLP State & Local Taxation,

It's no secret that the state of California is in a dubious position, facing considerable debt in the wake of our Nation’s recent recession. In order to increase revenue, Governor Jerry Brown has proposed a series of tax increases that will appear on voting ballots next week. One of the...

South Korean government cracks down on offshore accounts

Posted on October 30, 2012February 19, 2019 by Moskowitz LLP International Taxation,

In the last 10 years, South Korea has seen an incredible surge in economic expansion. The country now represents the fourth largest economy in Asia, and the capital city of Seoul - particularly its Gangnam neighborhood - has become a capitalist paradise teeming with big-name brands and luxury boutiques. However,...

Is Steven Seagal Above the Law when it comes to his tax debt?

Posted on October 26, 2012February 19, 2019 by Moskowitz LLP Criminal Tax Law, Tax: Audits, Litigation & Collection,

Since the State started publishing the names of the individuals who owe the largest amounts, the FTB has collected more than $100 million in delinquent tax debt. Because of the amounts collected, California has gotten even more aggressive with their efforts. For instance, a new state law (AB 1424, Perea),...

False return lawsuits spur IRS into action

Posted on October 18, 2012February 19, 2019 by Moskowitz LLP Tax: Audits, Litigation & Collection,

Last August, CNBC reported an alarming form of identity theft that undoubtedly made U.S. taxpayers worried: tax refund fraud. According to a report released by the IRS inspector general, the government body had doled out billions of dollars in refunds to scam artists that had filed fraudulent returns under the...

Offshore Amnesty Penalties: An Unfortunate Driving Force for Renouncing Citizenship

Posted on September 24, 2012February 19, 2019 by Moskowitz LLP International Taxation,

Moskowitz LLP, A Tax Law Firm, regularly counsels individuals with foreign connections on U.S. taxation issues, facing offshore amnesty penalties. Here in San Francisco and the Silicon Valley, in particular, and California in general, we have recently seen an increase in individuals considering renouncing their U.S. citizenship1 and green cards...

Just how is the Expatriation Tax Calculated?

Posted on September 11, 2012April 1, 2022 by Moskowitz LLP International Taxation,

Introduction It has been all over the news lately, wealthy U.S. taxpayers, such as, Eduardo Saverin (a Facebook founder), Denise Rich (songwriter), and another eighteen hundred, or so, have forfeited their U.S. citizenship for U.S. tax reasons. Federal law provides that some U.S. taxpayers who elect to renounce their U.S....

U.S. Tax Effects of Treaties in the Context of Foreign Investment in the U.S.

Posted on September 6, 2012February 19, 2019 by Moskowitz LLP International Taxation, Real Estate Law,

Introduction Foreign investors in the U.S. tend to have the same goals as their U.S. counterparts. Like U.S. taxpayers, foreign investors seek to minimize their income tax liabilities associated with their U.S. real estate and business investments. However, foreign investor’s objectives are clouded by the fact that they are not...

Are you eligible for federal employment if you owe taxes?

Posted on September 3, 2012February 19, 2019 by Moskowitz LLP Tax: Audits, Litigation & Collection,

Legislation Pending to Require Higher Tax Accountability for Federal Employees On July 31, 2012, the United States House of Representatives passed H.R. 828, also known as the “Federal Employee Tax Accountability Act of 2012”, by a majority of 263 to 114. It has since been referred to the United States...

Piercing Asia – U.S. Offshore Bank Account Crackdown results in data on undeclared bank accounts with Hong Kong Connections

Posted on August 24, 2012February 19, 2019 by Moskowitz LLP International Taxation,

On August 20, 2012, the United States Attorneys Office issued a press release regarding their most recent Offshore Bank Account Plea Agreement reached. The taxpayer, Jacquez Wajsfelner pled guilty to willfully failing to file foreign bank account reports (FBAR) for several Swiss Bank Accounts. Slightly outside the average age of...

Non-Citizens Risk Immigration Status for Offshore Bank Accounts

Posted on August 22, 2012February 19, 2019 by Moskowitz LLP International Taxation,

The increased focus by the IRS on foreign income has generated a lot of news and a slew of criminal prosecutions. While US citizens need to consider the possibility of monetary penalties or a long prison sentence, resident non-citizens (green card holders) also need to worry about the possibility of...

Federal Tax Crimes: Korean Roofer Sentenced to 3 1/2 years

Posted on August 22, 2012February 19, 2019 by Moskowitz LLP Criminal Tax Law,

On Wednesday, August 8, 2012, Tae Son Lee (aka, Mike Lee), age 52, of Oakland, California was sentenced to three and a half years in prison for Federal Tax Crimes stemming from his roofing business, also in Oakland, CA. The Internal Revenue Service (IRS) conducted an investigation stemming from his...

U.S. Taxation of Fideicomisos under the FATCA Rules

Posted on August 7, 2012February 19, 2019 by Moskowitz LLP Tax: Audits, Litigation & Collection,

Overview of Fideicomisos If you own a home or a vacation home in Mexico, chances are that your property is held in a fideicomiso. A fideicomiso is a contractual arrangement that is arguably something in between a trust and a custodial agreement. Under Mexican law, a fideicomiso is a written...

Tax Return Preparers, Crimes, and Penalties

Posted on August 2, 2012February 19, 2019 by Moskowitz LLP Criminal Tax Law, Tax Planning & Compliance, Tax: Audits, Litigation & Collection,

with thanks to Elizabeth E. Prehn, Law Clerk The Internal Revenue Service and lawmakers across the nation have introduced a bill to Congress to Increase Tax Preparer Penalties. While this bill, introduced as the Fighting Tax Fraud Act, is aimed at blatant schemes by tax preparers to defraud taxpayers, it...

Tax Lawyer Blog

How can we help you today?