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

Offshore Bank Account and Asset Alert: March 2014

Posted on March 31, 2014February 19, 2019 by Moskowitz LLP International Taxation,

Another 106 Banks will be turning over customer information to the United States Department of Justice (DOJ) - What this means for those with Offshore Bank Accounts and Assets - Especially in Japan, Hong Kong, Taiwan, Mainland China, and South Korea The United States has succeeded in obtaining huge fines...

Think the Government isn’t serious about Offshore Bank Accounts?

Posted on February 19, 2014February 19, 2019 by Moskowitz LLP International Taxation, Criminal Tax Law,

Think that if you have offshore assets and you get caught, that you can just pay the Government? Think Again. Beanie Babies creator Ty Warner was sentenced to two years probation as a result of his offshore bank accounts. Remember, he tried to come forward and take part in the...

Offshore Voluntary Disclosure and Tax Compliance

Posted on February 9, 2014February 19, 2019 by Moskowitz LLP International Taxation, Tax Planning & Compliance,

Our team of experienced tax attorneys can help you become compliant with the Internal Revenue Service and minimize or eliminate your exposure to any offshore penalties and other problems. Offshore Voluntary Disclosure Representation One option individuals who have unreported foreign bank accounts and have underreported or failed to disclose foreign...

Pre-Immigration Tax Planning

Posted on January 22, 2014February 19, 2019 by Moskowitz LLP International Taxation, State & Local Taxation, Tax Planning & Compliance,

The decision of a nonresident alien to move to the United States and become a U.S. citizen or resident alien will invoke significant tax considerations involving the interaction of the tax systems of the United States and the alien's current country of residence. This includes both consequences under U.S. law...

Qualified Quiet Disclosure

Posted on January 14, 2014February 19, 2019 by Moskowitz LLP International Taxation, Tax Planning & Compliance,

Several options exist for individuals with prior undisclosed foreign assets and/or income to become compliant with the IRS. Two of the more commonly used choices are the Qualified Quiet Disclosure and the Offshore Voluntary Disclosure Program ("OVDP"). Taxpayers entering into the Offshore Voluntary Disclosure Program must agree to several requirements. ...

Citizens of China can invest in US real estate and pay no tax

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

With the rapid growth of Chinese economy, overseas property and investment has become a new investment concept for many citizens of China. Domestic policies for house-purchase restrictions and controls, in addition to the global real estate boon, have stimulated the formation of the buyer's in China for overseas property. Further,...

How will FATCA affect your retirement plans abroad?

Posted on October 31, 2013February 19, 2019 by Moskowitz LLP Tax Planning & Compliance, International Taxation,

It is becoming increasingly common for Americans of retirement age to spend their golden years abroad. The most common reasons for this is to live in a more favorable climate and to save money. Living on a pension or other retirement income can go much further in many countries than...

FINDING OFFSHORE BANK ACCOUNTS & REAL ESTATE: IN CHINA

Posted on October 4, 2013February 19, 2019 by Moskowitz LLP International Taxation, Tax Planning & Compliance,

China has now joined the U.S.' efforts to combat tax evasion by entering into the Multilateral Convention on Mutual Administrative Assistance in Tax Matters effective August 27, 2013. The gravamen of this new treaty with China is that the U.S., by and though the U.S.'s FATCA, will be able to...

DOJ: Hiding assets in Switzerland is ‘beyond foolish’

Posted on September 12, 2013February 19, 2019 by Moskowitz LLP International Taxation, Criminal Tax Law,

U.S. citizens and permanent residents are required by law to report any assets held in foreign bank accounts to the Internal Revenue Service (IRS). With the upcoming implementation of the Foreign Account Tax Compliance Act (FATCA), it will be extremely difficult for Americans to conceal funds held in other countries....

San Francisco man admits hiding foreign bank account

Posted on September 9, 2013February 19, 2019 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...

Cayman Islands and the Foreign Account Tax Compliance Act

Posted on August 18, 2013February 19, 2019 by Moskowitz LLP International Taxation, Tax Planning & Compliance,

The United States and the Cayman Islands have reached an agreement to begin implementation of the Foreign Account Tax Compliance Act (FATCA). The purpose of FATCA, enacted by the United States in 2010 taking effect in 2014, is to combat offshore tax evasion. Now that the Cayman Islands have signed...

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)...

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