Anthony Diosdi

Anthony Diosdi

Moskowitz LLP

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Can an OVDP Participant Set Aside a Closing Agreement on the Theory of Duress?

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...more

7/15/2014 - Closing Documents Duress FBAR FinCEN IRS OVDP Tax Evasion

The Qualified Quiet Disclosure: Operating Outside Of The IRS Offshore Voluntary Disclosure Initiative

Individuals with previously undisclosed foreign assets and/or income have a variety of options to become compliant with the IRS, with two avenues for resolution being the most common: Qualified Quiet Disclosure and the...more

11/13/2013 - Compliance Disclosure Disclosure Requirements FBAR IRS OVDP Voluntary Disclosure

The Government Shutdown - Great News For Some Taxpayers

The budget impasse has suspended audits conducted by the Internal Revenue Service (“IRS”) and cases currently being litigated before the United States Tax Court. This will undoubtedly be a huge opportunity for a number of...more

10/7/2013 - Government Shutdown IRS Tax Liability

What A Tax Attorney Can Do for You: Understand How Apple, Inc. Legally Does Not Pay Income Tax

When Apple Inc., disclosed that it has not paid any corporate income tax over the past 4 years, it got the government’s attention. Hailed before the Senate, Apple is confident in their tax position because, it is legal. ...more

5/22/2013 - Apple Corporate Taxes Income Tax Treaty Subsidiaries Tax Liability

Collection Due Process Hearings: Is It A Second Chance For Taxpayers To Litigate A Matter Previously Missed?

It happens all the time. Taxpayers are assessed tax liabilities by the Internal Revenue Service (IRS). To make matters worse for many taxpayers, they fail to timely petition the United States Court to contest the assessment....more

4/1/2013 - Collection Due Process Hearings IRS Jurisdiction Notice Requirements Tax Assessment

The State Of California Seeks Back Taxes From Small-Business Shareholder- Not So Fast

A closer look at federal constitutional case law would seem to indicate that the State of California may not find it so easy to seek refunds plus interest after all....more

2/14/2013 - Commerce Clause Cutler v Franchise Tax Board Foreign Corporations Franchise Tax Board Income Taxes Qualified Small Business Stock Retroactive Application Retroactive Taxes Tax Deferral

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