Moskowitz LLP

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180 Montgomery Street
Suite 1950
San Francisco, CA 94104, United States
Phone: (415) 394-7200
Areas of Practice
  • Criminal Law
  • International Law & Trade
  • Litigation
  • Taxation
Locations
Other U.S. Locations
  • California
Number of Attorneys
2-10 Attorneys

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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Undisclosed Foreign Accounts, Part II

The executor of a decedent’s estate has a duty to act in a prudent manner and in accordance with the law. At times, this may result in having to take an unpopular position or action that angers the beneficiaries…more

Beneficiaries, Civil Liability, Criminal Liability, Decedent Protection, Estate Planning

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