Moskowitz LLP

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

  • (415) 394-7200

Crackdown on Tax Treaty Abuses

Tax authorities throughout the world are cracking down on taxpayers – individuals and corporations – that utilize some aggressive tax planning strategies…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Taxation

The Corporate Inversion: From Obscure Strategy to Hot Trend

Capitalist ideals of “free enterprise” and “competition” make great debate topics, but when compared to the business-friendly tax codes of other nations the United States Tax Code cannot compete. With the highest corporate…more
| Commercial Law & Contracts, Mergers & Acquisitions, International Law & Trade, Taxation

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
| Civil Procedure, Commercial Law & Contracts, Criminal Law, International Law & Trade, Taxation

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 Offshore…more
| Criminal Law, Finance & Banking, International Law & Trade, Taxation

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
| Elections & Politics, Taxation

What The New Tax Treaty With China Means For Those Who Have Bank Accounts In China

SAN FRANCISCO, CA,– 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 on August 27, 2013. The gravamen of this new…more
| Finance & Banking, International Law & Trade, Taxation

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
| Business Organizations, Commercial Law & Contracts, Intellectual Property, International Law & Trade, Taxation

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. In…more
| Civil Procedure, Constitutional Law, Taxation

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
| Business Organizations, Constitutional Law, Securities Law, Taxation

Feeling Generous This Year?

Giving to others is rewarding in and of itself, but it's always nice to see your generosity provide you with a tax benefit and result in a lower tax bill. In our tax law practice we represent many individuals and one of the…more
| Finance & Banking, Taxation, Wills, Trusts, & Estate Planning

Same-sex married couples: Consider filing a Protective Claim for Tax Refund NOW

Being based in San Francisco, CA, our attorneys, CPAs, and staff watched thousands of same-sex couples marry at San Francisco and Oakland City Halls during the window of opportunity to do so. If you are one of the nearly…more
| Civil Rights, Family Law, Taxation

District Court Decides FBAR Penalty Assessment Case - Both A Win For The Government & For OVDP Participants

Here at Moskowitz LLP, A Tax Law Firm based in San Francisco, CA, we have been following just how the Internal Revenue Service will collect FBAR penalties once imposed outside the scope of any Offshore Amnesty Program. …more
| Constitutional Law, Criminal Law, International Law & Trade, Taxation

IRS Form 1099 Enforcement Program - Another Fishing Expedition?

The Housing Assistance Tax Act of 2008 included a new IRS mandate that requires certain companies that settle payments for merchants and other payment processors to report the gross sales of the transactions to the IRS each…more
| Commercial Law & Contracts, Taxation

Prop. 30 proposes higher income tax for well off in California

It's no secret that the state of California is in a dubious position, facing considerable debt in the wake of our Nation’s recent recession. In order to increase revenue, Governor Jerry Brown has proposed a series of tax…more
| Elections & Politics, Taxation

South Korean government cracks down on offshore accounts

In the last 10 years, South Korea has seen an incredible surge in economic expansion. The country now represents the fourth largest economy in Asia, and the capital city of Seoul - particularly its Gangnam neighborhood - has…more
| Administrative Law, Finance & Banking, International Law & Trade, Taxation
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Areas of Practice
  • Criminal Law
  • International Law & Trade
  • Litigation
  • Taxation
Locations
Other U.S. Locations
  • California
Number of Attorneys

2-10 Attorneys

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