International Tax Representation
International Tax The Law Offices of Stephen Moskowitz offers its clients a comprehensive array of international tax services. We prepare federal and multi-state tax returns for United States expatriates and foreign nationals. We also provide our clients with international tax planning advice which includes planning for inbound and outbound transactions. In addition, we analyze international tax treaties and advise our clients on favorable tax positions in regards to international tax treaties.
Below are some representative cases our firm has handled
- Represented a United States taxpayer accused by the IRS of failing to file to file a Report of Foreign Bank and Financial Accounts Form 22.1 (“FBAR”) for bank accounts he held in the Bahamas. The IRS threatened to assess significant penalties against our client and opened a full audit of our client’s tax returns. Because our client did not have foreign bank accounts exceeded $10,000 at any time during the years in question, we were able to convince the IRS not to assess any additional taxes or penalties against our client.
- Represented a US taxpayer accused of failing to file the correct forms with the IRS for corporations, partnerships, trusts, and bank accounts established in certain tax haven countries. Not only did the IRS propose to assess our client with an extremely large tax liability, penalties, and interest, they also sought to charge the client with numerous currency offenses. Our attorneys achieved an exceptionally favorable settlement for our client and convinced the IRS not to assess any currency related penalties.
- Represented a United States taxpayer accused by the Department of Treasury of violated the Bank Secrecy Act by not properly reporting to the government international wire transfers that were taking place from his business. Since the client did not willful fail to properly report the wire transfer transactions to the government, our attorneys were able to convince the IRS not to assess any penalties against our client.
- Advised a United States corporation and its shareholders regarding the tax consequences of a captive insurance company based in Caribbean.
- Advised Canadian national on the tax aspects of her U.S. transactions and represented her before an IRS examination of her U.S. tax returns.
- Advised a U.S. taxpayer residing in Ireland of tax credits and income exclusions potentially available to her.
- Analyzed the tax equalization position taken by a major accounting firm on the tax return of a U.S. taxpayer employed in Saudi Arabia. Provided our client with advice how to amend his tax return to claim a far more favorable position on his tax returns.
* The results in the cases mentioned above were dependent on the facts of that particular case, and the results differ if based on different facts
