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

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...

United States and South Korea Coordinate to Combat Monetary & Tax Crimes

Posted on August 2, 2012February 19, 2019 by Moskowitz LLP International Taxation,

To combat money and tax crimes, such as tax evasion and money laundering, the United States and Korean Governments have committed to a simultaneous criminal investigation program, SCIP. The arrangement allows the respective tax departments; the United States’ Internal Revenue Service (IRS) and South Korea’s National Tax Service (NTS), to...

Why Am I Being Audited?

Posted on July 20, 2012February 19, 2019 by Moskowitz LLP Tax: Audits, Litigation & Collection,

Why Am I Being Audited? Often asked in mournful tones, it's a question we hear from new clients all the time: "Why am I being tortured with an audit?" Here is a look at a couple reasons why you may be facing an IRS audit: 1. Matching notices: A matching...

Franchise Tax Board’s Automatic Calls – What You Need to Know

Posted on July 12, 2012February 19, 2019 by Moskowitz LLP State & Local Taxation,

On July 10, 2012, the California State Franchise Tax Board (FTB) announced that it would implement an automatic dialer system to make outbound calls to individuals to further enhance their collection efforts; which include, but are not limited to, tax liens, bank levies, garnishments ,etc. Businesses will begin to receive...

FBAR Filing Deadline – Receipt on or before June 30

Posted on June 26, 2012February 19, 2019 by Moskowitz LLP International Taxation, Tax Planning & Compliance,

Foreign Bank Account Report, Treasury Department Form 90-22.1 (FBAR) Who Must File an FBAR: Generally, every U.S. person with a financial interest in or signature or other authority over, any financial account outside of the United States, must file an FBAR if the aggregate value of all accounts exceeds $10,000...

IRS is releasing new guidelines for 2012 OVDP

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

The Internal Revenue Service will be providing new guidelines to the Offshore Voluntary Disclosure Program (OVDP) which address such issues as the number of years at issue (there has been much debate amongst tax attorneys as to whether it is 3, 6, 8, or more). We also expect it to...

Lauryn Hill’s unfiled tax returns leads to criminal charges

Posted on June 12, 2012February 19, 2019 by Moskowitz LLP Criminal Tax Law,

On June 7, 2012, Grammy winner Lauryn Hill was indicted for failing to file back income tax returns with the Internal Revenue Service. The criminal information charges that Ms. Hill failed to file income tax returns for tax years 2005, 2006, and 2007. Typically having unfiled tax returns will not...

Yahoo Reports: Lauryn Hill Says She Didn’t Pay Taxes Because She Went ‘Underground’.

Posted on June 10, 2012February 19, 2019 by Moskowitz LLP Tax: Audits, Litigation & Collection,

To that statement, as a practicing tax lawyer, my experience has taught me that a lot of people go underground because they cannot pay their taxes. Going underground does the individual an enormous disservice. They go underground one year and then are scared to file the next year because they...

Foreign Account Tax Compliance Act (FATCA)

Posted on May 28, 2012February 19, 2019 by Moskowitz LLP Tax: Audits, Litigation & Collection,

The Foreign Account Tax Compliance Act (FATCA) is another way that the Internal Revenue Service and U.S. Department of Treasury will be able to identify your income and assets outside of the United States. Under FATCA, U.S. taxpayers with foreign assets that exceed certain thresholds must report those assets to...

Aggressive, Accessible, and Experienced Tax Attorneys

Posted on March 14, 2012February 19, 2019 by Moskowitz LLP Tax: Audits, Litigation & Collection,

Welcome to the Moskowitz, LLP. Our Tax Attorneys have over three decades of experience representing clients (individuals, small businesses, corporations, municipalities, multi-million dollar businesses, trusts, estates, and other entities and organizations) with their tax matters. We are committed to obtaining results for our clients with skilled, calculated legal representation and...

Supreme Court Decides that Filing a False Tax Return for Resident Aliens is an “Aggravated Felony” that Prompts Deportation Proceedings.

Posted on March 7, 2012February 19, 2019 by Moskowitz LLP Criminal Tax Law,

The Supreme Court of the United States has recently affirmed that pleading guilty to or assisting in the filing a false tax return is considered an "aggravated felony," which is a deportable offense. This means that a resident alien can be immediately deported if he pleads to or is convicted...

2012 Offshore Voluntary Disclosure Program; One Size Does Not Fit All

Posted on February 2, 2012February 19, 2019 by Moskowitz LLP International Taxation,

The Internal Revenue Service (IRS) announced a recent third Offshore Voluntary Disclosure Program (OVDP) for U.S. taxpayers with unreported foreign income or financial accounts. The OVDP eliminates potential criminal penalties and greatly reduces the civil (monetary) penalties for U.S. taxpayers with previously undisclosed foreign income and assets. In most cases,...

Who does the Internal Revenue Service consider a Tax Preparer? Exploring Applicable Law

Posted on January 31, 2012February 19, 2019 by Moskowitz LLP Tax Planning & Compliance,

Who does the Internal Revenue Service consider a tax preparer? For such a simple question, the answer can be complicated. This is an important question for attorneys, accountants, Enrolled Agents, or other professionals. Tax returns that show substantial understatements due to tax preparer error, whether it be intentional or not,...

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