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

Audit Enforcement and Audit Plan Strategies

Posted on February 10, 2011February 20, 2019 by Moskowitz LLP Business Law, Tax Planning & Compliance,

Audit Plan Strategies The Treasury Inspector General for Tax Administration (TIGTA) is responsible for monitoring and directing the IRS's activities. Recently, the TIGTA estimated that taxpayers will owe $345 billion more than what they actually claim they owe on their income tax returns this year. Because they are expecting this...

BANK SECRECY ACT, An Overview

Posted on January 26, 2011February 20, 2019 by Moskowitz LLP Business Law, Tax Planning & Compliance,

Passed in 1970, the Bank Secrecy Act (BSA) was the first set of laws specifically designed to combat money laundering. In fact, it is sometimes referred to as the "Anti-Money Laundering Law (AML)" or "BSA/AML." The BSA has been amended over the years by the addition of other anti-money laundering...

History of the Internal Revenue Service’s Voluntary Disclosure Program

Posted on January 5, 2011February 20, 2019 by Moskowitz LLP International Taxation, Criminal Tax Law, Tax: Audits, Litigation & Collection,

This is a two-part blog post on the evolution of IRS voluntary disclosure programs. The first post traces these programs from their inception through the 1990's. The second post discusses the programs beginning in 2000 and carrying through to the present day. Overview Since the Justice Department sued UBS in...

Federal Tax Calendar

Posted on January 1, 2011February 20, 2019 by Moskowitz LLP State & Local Taxation, Tax Planning & Compliance,

Federal Tax Calendar - 2011 January 10 — Employees who work for tips If you received $20 or more in tips during December, report them to your employer. January 18 — Individuals Pay your estimated tax for 2010 using Form 1040-ES. January 18 — Farmers & fishermen Pay your estimated...

IN 2010 -THE WORLD BECOMES SMALLER AND IS NOW TAX TRANSPARENT

Posted on December 31, 2010February 20, 2019 by Moskowitz LLP Tax Planning & Compliance, International Taxation,

INTERNATIONAL TAX PREPARATION FOR BUSINESSES AND INDIVIDUALS On March 18, 2010, the Foreign Account Tax Compliance Act (FATCA) was enacted into law. The scope of FATCA is extremely broad. Almost every foreign financial institution is within reach of this new law. FATCA requires any foreign financial institution that holds any...

White Collar Crime, Structuring

Posted on December 27, 2010February 20, 2019 by Moskowitz LLP Business Law, Criminal Tax Law, Tax Planning & Compliance,

Federal law requires business and financial institutions to report currency transactions in excess of $10,000 in a single or “related” transaction within a twelve-month period. Businesses must file an IRS form 8300 and financial institutions must file a currency transaction report. Even though making a deposit or withdrawal greater than...

Money Laundering: An Overview

Posted on December 8, 2010February 20, 2019 by Moskowitz LLP Criminal Tax Law, Business Law,

In our white collar crime/financial crime defense practice, we often see money laundering schemes. Money laundering is a term used for the criminal practice of moving illegally-acquired funds through various transactions so that the money ends up “looking” like it came from some legal activity. Money launderers attempt to hide...

San Bruno Fire Victims, Disaster Tax Losses

Posted on December 7, 2010February 20, 2019 by Moskowitz LLP State & Local Taxation,

Victims of disaster are often faced with immediate and severe economic hardships. Fortunately, the California Franchise Tax Board (FTB) and the State Legislature has provided a way for victims of the San Bruno Fire disaster to obtain the financial relief to which they are entitled in an expeditious manner. This benefit...

Tax Tales: Married Couples Filing Separate Taxes

Posted on December 2, 2010February 20, 2019 by Moskowitz LLP Tax Planning & Compliance, State & Local Taxation, Tax: Audits, Litigation & Collection,

In today’s age of technology we enjoy access to information at the push of a button. The latest advances in technology not only benefit us greatly, but also the government. After 9/11, the Patriot Act gave the government more access to financial institutions both domestic and foreign. Personal and business financial...

NEW 1099 FILING REQUIREMENTS

Posted on November 23, 2010February 20, 2019 by Moskowitz LLP Tax Planning & Compliance, Business Law,

By now most people have heard something about the massive health care overhaul that will occur due to the passage of section 9006 of the new Health Care Reform Bill. Many companies are trying to figure out how the bill will affect their medical plans and related expenses. However, they...

INTERNAL REVENUE CODE SECTION 7623: THE WHISTLEBLOWER STATUTE

Posted on November 23, 2010February 21, 2019 by Moskowitz LLP Criminal Tax Law, Business Law,

Under the Internal Revenue Code, individuals acting as “whistleblowers” by reporting underpayment of taxes or violation of tax laws by another taxpayer may be awarded money from the amount collected by the government. To be eligible for a section 7623 award, the disputed amount must exceed two million dollars, and...

UNLIMITED LOSS DEDUCTIONS FOR REAL ESTATE PROFESSIONALS

Posted on November 23, 2010February 21, 2019 by Moskowitz LLP Real Estate Law,

Owning rental property may yield large financial gains in healthy markets. Recently, however, fluctuations in the real estate and housing markets have produced conditions which can lead to great financial losses. Because owning real estate is considered a “passive activity” by the tax code, there are certain restrictions and limitations...

Wesley Snipes to serve three years in federal prison for not filing tax returns

Posted on November 19, 2010February 21, 2019 by Moskowitz LLP Tax Planning & Compliance, Criminal Tax Law, Tax: Audits, Litigation & Collection,

Owing taxes is not a crime, but his willfully not filing a tax return is San Francisco, CA - It is not a crime to owe money to the IRS. If Wesley Snipes had filed his tax returns but couldn't pay he would not be going prison. Willfully not filing is where...

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