Contesting an IRS Summons: The Impact of United States v. Clarke

Posted on by Moskowitz LLP Tax: Audits, Litigation & Collection, Criminal Tax Law,
The Supreme Court recently issued a brief but significant ruling concerning a taxpayer's right to contest an IRS summons. Per 26 U.S.C. 7602, the IRS has a right to request information from a taxpayer through examination of books, papers, records, testimony, etc. pursuant to a civil or criminal IRS investigation....
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Can an OVDP Participant Set Aside a Closing Agreement on the Theory of Duress?

Posted on by Moskowitz LLP International Taxation, Criminal Tax Law, Tax: Audits, Litigation & Collection,
I. Introduction and History of the Targeted Offshore Voluntary Disclosure Programs Offered by The IRS It has been just over five years since the Internal Revenue Service (“IRS”) offered the first of three offshore voluntary disclosure programs for individuals with undisclosed foreign financial accounts. Since the announcement of the first...
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The IRS’s Position Regarding Disclosures Made Outside a Targeted Voluntary Disclosure Program

Posted on by Moskowitz LLP International Taxation, Criminal Tax Law,
Other Posts in this Series A History of the IRS’s Targeted Offshore Voluntary Disclosure Programs Pursing a Claim for the Refund of a Penalty Paid Through an Offshore Voluntary Disclosure Program Part Four: Examining the Limitations a Closing Agreement Places on Tax Litigation OVDP Penalty Refund - Setting Aside the...
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Offshore Initiative – Another NPA reached: DOJ 23.8 million settlement with Liechtensteinische Landesbank AG (LLB-Vaduz)

Posted on 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...
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