Moskowitz LLP

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 of…more

Closing Documents, Duress, FBAR, FinCEN, IRS

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Foreign Bank Account Reporting and Employment Tax Enforcement: Ronn Owens interviews Steve Moskowitz

Ronn Owens interviewed Steve Moskowitz on June 28 and they discuss IRS priorities, including Foreign Bank Account Reporting and Employment Tax Enforcement. Steve and Ronn further discuss the history of individual tax rates and…more

Alternative Minimum Tax, Employment Tax, Foreign Bank Accounts, IRS, Tax Evasion

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The Administrative Procedure Act - Challenging FBAR Penalties

Over the past 10 years, thousands of U.S. taxpayers with a wide variety of circumstances have been forced to pay extraordinarily high penalties for failure to disclose foreign bank accounts. For years, tax experts said that the…more

Administrative Procedure Act, Civil Monetary Penalty, Delegation Clauses, Due Process, Eighth Amendment

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180 Montgomery Street
Suite 1950
San Francisco, CA 94104, United States

  • (415) 394-7200

Areas of Practice
  • Criminal Law
  • International Law & Trade
  • Litigation
  • Taxation
Other U.S. Locations
  • California
Number of Attorneys

2-10 Attorneys

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