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

Foreign Investments – Compliance & Disclosure Issues

Posted on May 10, 2011February 10, 2021 by moskowitz International Taxation, Tax Planning & Compliance,

As the national markets grow global, many American investors find themselves with potentially lucrative but highly complicated foreign investment opportunities. While the investments themselves and the returns thereon may be fairly simple and straightforward, the tax treatment of those investments is anything but simple and straightforward. While trying to catch...

Passive Foreign Investment Companies and Tax Treatment – Understanding Pfic Reporting

Posted on April 28, 2011February 10, 2021 by moskowitz International Taxation,

With the heightened interest in U.S. connected people and businesses in offshore banking, it is important to understand the importance of properly to the Internal Revenue Service and various State taxing agencies of foreign bank accounts and investments. The Federal income tax rules regarding those who have interest in any...

U.s. Department of Justice and the Internal Revenue Service Expand Collection Efforts Internationally

Posted on March 31, 2011February 20, 2019 by moskowitz Tax: Audits, Litigation & Collection, International Taxation, Tax Planning & Compliance,

As individuals and companies take advantage of international tax benefits or previously undetected avenues of sheltering money from taxes and creditors, the Internal Revenue Service (IRS) is now concentrating more of its efforts on overseas tax compliance and collection. IRS Commissioner Douglas H. Shulman called global tax administration efforts a...

2011 Voluntary Disclosure Initiative (ovdi) for Unreported Offshore Accounts

Posted on March 29, 2011February 20, 2019 by moskowitz Criminal Tax Law, International Taxation,

There has recently been a flurry of press surrounding the IRS' announcement of a new 2011 Voluntary Disclosure Initiative (OVDI) for offshore accounts. This program is part of the Department of Justice's targeting of offshore bank account holders who fail to report income associated with the account on their U.S....

Voluntary Disclosure Initiative

Posted on February 23, 2011February 20, 2019 by moskowitz International Taxation, Criminal Tax Law,

"Last & Best" 2011 Offshore Voluntary Disclosure Initiative On February 8, 2011, the Internal Revenue Service announced the "last and best" voluntary disclosure program for those with offshore accounts. The official name of the program is the "2011 Offshore Voluntary Disclosure Initiative" (OVDI). This new program is scheduled to run...

History of the Internal Revenue Service’s Voluntary Disclosure Program

Posted on January 5, 2011February 20, 2019 by moskowitz 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...

In 2010 -the World Becomes Smaller and Is Now Tax Transparent

Posted on December 31, 2010February 20, 2019 by moskowitz 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...

Foreign Bank Accounts and the Voluntary Disclosure

Posted on November 3, 2010June 11, 2018 by moskowitz International Taxation, Criminal Tax Law,

Introduction For many years a large number of U.S. taxpayers have placed and may continue to place, money in foreign bank accounts. Many of these individuals, knowingly or unknowingly, violate federal law by not disclosing these foreign accounts on their federal income tax returns. In an effort to step-up enforcement...

Swiss Government Approves Ubs-u.s. Tax Deal

Posted on June 1, 2010June 11, 2018 by moskowitz International Taxation, Criminal Tax Law,

Both house of the Swiss parliament have finally approved a tax treaty with the United States. The change in Swiss law means that Switzerland’s biggest bank, United Bank of Switzerland (UBS) will hand over to the United States Department of Justice the details of nearly 4,500 of their U.S. clients....

Us Tax Consequences to Foreign Investors

Posted on January 2, 2010June 11, 2018 by moskowitz Tax Planning & Compliance, International Taxation,

During the past few decades the United States has received a massive influx of foreign investment from abroad. Much of these international investors are unaware of the domestic tax consequences of investing in the United States. Foreign investors may be subject to US domestic taxation simply by investing or traveling...

Offshore Bank Account Holders Missed Irs Offer That Expired October 15, 2009! Now What?

Posted on October 15, 2009January 26, 2021 by moskowitz Criminal Tax Law, International Taxation,

This blog is outdated, but our tax law firm is still helping taxpayers who have not reported their foreign income to avoid civil and criminal penalties. Learn more about our FBAR and foreign account reporting services or simply contact our California offices today. The IRS has steep penalties and even...

October 15, 2009 Deadline for Voluntary Disclosure

Posted on October 2, 2009June 11, 2018 by moskowitz International Taxation, Criminal Tax Law,

United States citizens who have an interest in, or signature or other authority over, a financial account in a foreign country with assets in excess of $10,000 are required to disclose the existence of such account on Schedule B, Part III of their individual income tax return. Additionally, U.S. citizens...

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