Welcome to the Moskowitz, LLP. Our Tax Attorneys have over three decades of experience representing clients (individuals, small businesses, corporations, municipalities, multi-million dollar businesses, trusts, estates, and other entities and organizations) with their tax matters. We are committed to obtaining results for our clients with skilled, calculated legal representation and providing personal, accessible service to meet the professional and personal tax needs of our clients.

Our Tax law firm, located in beautiful San Francisco, CA, provides civil tax, criminal tax, and related tax representation locally, as well as nationally and internationally. Our tax practice covers the entire spectrum of individual and business needs. We pride ourselves with our continual innovation and prudent creativity when it comes to case management, strategizing for, and when necessary, vigorously defending, our clients.

Our tax controversies practice involves, but is not limited to, the following:

• IRS and State practice and procedure: examination and appeals,
• Trial court litigation in the Tax Court, Court of Federal Claims and numerous courts,
• Criminal tax investigations and defense,
• State and local tax controversy and litigation,
• Foreign Reporting & Off-Shore compliance/investigation issues,
• Disclosure programs

In addition to tax controversies, we routinely provide representation with regard to:

• Tax return preparation (delinquent and current year),
• Transactional planning,
• Legal Opinion preparation,
• Asset protection/Wealth management,
• Tax delinquency resolution (collection representation),
• White Collar Crime defense.

We begin every engagement by clearly understanding the priorities of our client, both short and long term, so that we thoroughly understand the circumstances, facts, and risk tolerance involved or potentially involved. We then apply our over 35 years of tax experience to provide thoughtful advice, skilled lawyering, and anticipatory insight to the matter at hand and potential future concerns or rewards. Further, unlike some attorneys, we are accomplished advocates and trial Attorneys; fluent in the tax law, we understand the circumstances in which tax issues arise, and through years of experience we know how tax disputes and criminal charges emerge and how to avoid or resolve them. When necessary, our tax litigators have tried numerous federal cases in the Tax Court, the U.S. Court of Federal Claims, Bankruptcy Courts, and various District Courts.

The Law Offices of Stephen Moskowitz, LLP, located in the financial district of San Francisco, California, represents clients in California, throughout the United States, and internationally, where we practice federal, state and international tax law. For questions concerning federal, state, international tax law, or to discuss your matter with tax Attorney Stephen Moskowitz, please call us at (415) 394-7200, or fill out our information request form on our contact us page for a free confidential consultation, either in person or by telephone.

The Supreme Court of the United States has recently affirmed that pleading guilty to or assisting in the filing a false tax return is considered an “aggravated felony,” which is a deportable offense. This means that a resident alien can be immediately deported if he pleads to or is convicted of certain tax crimes.

The decision has far-reaching and detrimental effects on lawful permanent residents in the United States because the Supreme Court decided that falsely filing a tax return involved an act of deceit or fraud (factors in immigration issues) even though deceit or fraud may not be part of the actual [tax] crime itself.

The Crime(s):

1. Akio Kawashima - pleaded guilty to willfully filing a false tax return,
2. Fusako Kawashima - pleaded guilty to aiding and assisting the preparation of a false tax return.

The Kawashima, a married couple native to Japan who became lawful residents of the U.S. in 1984. They ran a successful restaurant chain called Cho Cho San in Thousand Oaks, California and Tarzana, California. The IRS determined that the total actual tax loss to the government was $245,126. At the time of this writing we do not have access to the indictment in the case, however, it is possible that they chose to plead to the false tax return charges in an effort to avoid tax evasion charges as tax evasion has been previously determined to be a deportable offense and carries higher prison sentences.

Shortly after the couple pled guilty, the Immigration and Naturalization Service (now the Department of Homeland Security) charged the Kawashimas with being deportable from the United States, under Title 8 of the United States Code.

Arguing that Filing False Tax Returns are Not Aggravated Offenses

The Kawashimas’ thus began a serious legal battle over whether filing a false tax return constitutes an aggravated felony leading to this Supreme Court Decision. 

The Supreme Court analysis was based on a statute dealing with immigration and naturalization issues.  An aggravated felony includes the crimes of murder, rape, sexual abuse of minors, illicit trafficking of firearms, money laundering, and running a prostitution ring.  As to tax crimes, Title 8 of the USC, provides that  an aggravated felony is defined as:

• (i) involves fraud or deceit in which the loss to the victim or victims exceeds $10,000; or
• (ii) is described in section 7201 of title 26 (relating to tax evasion) in which the revenue loss to the Government exceeds $10,000.  
  See USC, Title 8 §1101(a)

First, Mr. Kawashima’s attorney argued that the term “aggravated felony” does not apply to them under the immigration deportation standards because the crime he pled to,  willfully making or subscribing a false tax return, does not specifically involve “fraud and/or deceit” (as needed for deportation matters).   In attempting to clarify the immigration standards, however, the Court held that meaning of “deceit” means the “act or process of deceiving (as by falsification, concealment, or cheating).    Therefore, once Mr. Kawashima pled to knowingly submitting a tax return that was false, the Court reasoned that he had also thereby committed a felony that involved ‘deceit.’

As such, this case may mean that taxpayers who are convicted or plead to willfully making or subscribing a false tax return are also guilty of acting in a deceitful offense. 
  
Scope of the Consequences

Tax Crimes: 

Justice Ginsburg, who wrote the dissent, pointed out the far reaching consequences of this case. She explained that any conviction by federal, state, or local taxing authority that involves an amount over $10,000 would render the resident alien taxpayer deportable.  For example, furnishing a false W-2, supplying false or fraudulent information to an employer, or filing an incomplete or false return to a municipality, may be considered misdemeanors in some jurisdictions, yet could be considered an aggravated felony with punishment of deportation.

The decision rendered in Kawashima v Holder, has far-reaching and life-changing effects for all citizens.  There are a number of resident aliens in the Bay Area who need to be aware of this new development. The Supreme Court has equated filing a false tax return as a crime on the same level as murder or rape for the purposes of deportation. The Supreme Court’s decision is in line with other efforts of Congress and the Commissioner of Internal Revenue within the last decade to enforce existing tax laws and to create new tax laws that punish varying degrees of tax crimes. 

Offshore Tax Compliance: 

This decision raises new questions about efforts to get taxpayers to report foreign accounts with the Offshore Voluntary Disclosure Program (OVDI/OVDP). If you decide to participate in the OVDI/OVDP program, see 2012 Offshore Voluntary Disclosure Program, are you now in jeopardy of deportation because of the Kawashima case? Currently, the IRS has publicly declared that they will not report taxpayers participating in the OVDI to the Department of Justice (DOJ) if they made a mistake by not including their foreign assets on past tax returns. However, the IRS has not mentioned that they will refrain from calling Homeland Security.  Added to this, are you also in jeopardy of being deported when the overseas financial institutions begin compliance with the Foreign Account Tax Compliance Act (FATCA) by submitting your financial information directly to the IRS? These questions are just the tip of the iceberg. 

01-2012 Tax Times Newsletter (pdf, 1.09 mb)

Just in time for the holidays, Congress passed, and President Obama approved, a short-term extension of the Temporary Payroll Tax Continuation Act of 2011. The deal ensures that the social security withholding tax on employees stays at the current rate for the next few months.

Instead of the payroll tax reverting back to the rate of 6.2 percent, the law keeps the rate at 4.2 percent until the extension ends in March, 2012. A jump in the payroll tax rate to 6.2 percent would have equated to an average tax increase of $1,000 per year for 160 million Americans. To put it in simpler terms, the typical worker’s salary in this country would have been reduced by approximately $40 per pay period without the law.

But not all wage-earners benefit from the temporary extension. The deal includes a “recapture” provision for high-wage earning employees who receive more than $18,350 during the two month period that the law is in effect. Such high-wage earners are slapped with an additional income tax equal to 2 percent for the two month period. This recapture tax is not subject to any deductions or credits. However, the good news for these high-wage earners is that the recapture tax could be abolished when congress returns from the winter recess to negotiate a full-year extension of the payroll tax.

The deal also included several non-tax related provisions. For one, it extended the emergency federal unemployment benefits by two months to ensure that approximately 1.8 million jobless workers would not run out of benefits in January. It also extended the so called “doc fix” by delaying for two months a scheduled 27 percent reduction in payments to Medicare physicians. And to appease Republicans, the law requires President Obama to decide within the next 60 days whether he will go along with the proposed construction of the Keystone XL oil pipeline.

Employers are urged to implement the new payroll tax rate as soon as possible but not later than January 31, 2012. Any offsetting adjustments for Social Security tax over-withheld during January should also be made as soon as possible but not later than March 31, 2012. Workers need not take any action to realize the short-term cuts as employers and payroll companies are tasked with handling the withholding changes.

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San Francisco tax attorney Steve Moskowitz said this year's program was structured so that participants had to admit to intentionally evading taxes.

"I found that horribly offensive," Moskowitz said. "A lot of people inadvertently violated a law they hadn’t even heard of."

Moskowitz said some immigrants don't know they have to pay taxes on foreign income and would like to come clean when they find out. But admitting tax avoidance in the amnesty program, he said, could potentially get them in trouble later.

Moskowitz also argued that the punishment for those who didn't participate – tax audits for up to 12 years instead of eight – is unconstitutional.

Cornez, the Franchise Tax Board's tax counsel, said the $50 million in additional...

Read More: http://californiawatch.org/dailyreport/states-tax-amnesty-program-raises-350m-13750

Small business owners are always looking for a way to save money; especially in this economy.  Many small business owners are not aware of the tax incentives that certain retirement plans offer.  This post will outline some of the cost-saving ways that can make a real difference to your bottom line that can also provide added security for you and your employees upon retirement.

Simplified Employee Pension (SEP)

A SEP is an employer-established IRA plan that can be established by a one person business or by a business owner with multiple employees.  A small business owner who establishes a SEP may contribute up to 25% of his or her compensation but not more than $49,000 (for tax year 2011).  The maximum amount of compensation that can be considered under an SEP plan for 2011 is $245,000. 

An SEP is attractive because it is straightforward.  For instance, there are no reporting requirements for a SEP.  The small business owner simply sets up the account, makes contributions and claims a 100% deduction on his or her tax return.  Another advantage of a SEP is that it can be created after the end of the tax year.  So long as the plan is established and contributions are made by the due date of the income tax return for the year (including extensions), the requirements for the SEP plan have been met.  This can be a significant benefit to a small business owner with cash flow problems. 

Savings Incentive Match Plan for Employees (SIMPLE) IRA

A SIMPLE IRA is a good plan for a business with a net annual income of $15,000 or less.  The employer must have not more than100 employees who earned $5,000 or more in the proceeding calendar year to qualify for a SIMPLE IRA.  Contributions to a SIMPLE IRA plan include an employee’s salary reduction contribution as well as an employer’s matching contribution which is generally up to 3% of the employee’s reduction contribution.  A small business owner who takes an annual salary can benefit immensely by making both types of contributions to his or her own account. 

For 2011, the maximum contribution limit that can be made to a simple plan is $11,500.  Note that employees that are 50 years or older may contribute an additional $2,500 annually. 

Unlike a SEP plan, a SIMPLE IRA must be established before September 30th for the tax year that the small business owner wishes to make a contribution.  Salary reduction contributions for each employer must be made within 30 days after the end of the month in which the amounts would have been paid to the employees.  However, matching contributions and non-elective contributions may be made by the due date of the income tax return for the year (including extensions).

401(k) Plan

For businesses with a net annual income above $15,000, a 401(k) may be preferred over a SEP or a SIMPLE IRA because it allows the small business owner to contribute more to the retirement plan.  As with an SEP or a SIMPLE IRA plan, a 401(k) plan has a salary deferral component and an employer contribution component.  For 2011, the maximum salary deferred contribution component is $16,500 (or $22,000 for those ages 50 or older).  Additionally, a small business owner can make a maximum employer contribution of 25% of his or her own compensation.  The total that can be contributed to a 401(k) plan in 2011 is $49,000 ($54,500 for those ages 50 or older) or 100% of compensation, whichever is less.

Deferrals to a 401(k) must be made no later than 30 days after which the contributions are received.  Thus, if a contribution was received on December 31, 2011, the deadline would be 30 days later.

One drawback to a 401(k) plan is that there is a reporting requirement.  Access Form 5500, Annual Return /Report on Employer Benefit Plan at: http://www.dol.gov/ebsa/5500main.html

As with the SEP and SIMPLE IRA plans, elective contributions made to the plan are generally made on a pre-tax basis.  By electing to defer his or her own compensation and by contributing to the employees plans, the small business owner can substantially reduce the taxable income for the business for the current year.  

Bankruptcy Protection

It is worth noting that retirement accounts under SEP, SIMPLE IRA and 401(k) savings accounts are generally completely protected from bankruptcy.  This is an added bonus for small business owners who struggle to survive in this economy and are unsure about what the future will hold for their businesses. 

Whether you are a small business owner trying to identify the right retirement plan for your employees or a solo practitioner looking to identify significant tax deductions for your business, the attorneys and tax professionals at the Law Offices of Stephen Moskowitz, LLP can help you.  Call me at 1-888-829-3325 or (415) 394-7200 for your attorney-client privileged consultation and let us help you devise the right retirement strategy for your situation.

Having a sound retirement strategy is an important component of good tax planning.  There are many different types of retirement plans that can provide you or your employees with substantial annual tax benefits.  This blog post outlines the various types of retirement plans and touches upon some of the tax benefits associated with each of them.

Defined Benefit Plan

Under the traditional defined benefit or pension plan, the employer pays the employee a specific amount of compensation each month after the employee retires.  The amount of compensation received by the employee after retirement is usually based upon a combination of the number of years worked and the average of the highest three consecutive years of the employee’s salary. 

Some defined benefit plans, such as cash balance pension plans, involve an employer crediting the employee each year with a percentage of their annual salary plus interest.  This amount is deposited into an account and the employer invests that money as it see fit.  Upon retirement, the employee has the option of taking the balance in one lump sum or converting it into an insurance product called an annuity. 

Employers offering defined benefit plans are permitted to deduct their annual contributions to the plan which can result in significant tax savings.  However, defined benefit and pension plans are becoming a thing of the past as companies are moving to less expensive options.

Traditional Individual Retirement Account (IRA)

A traditional IRA is a personal savings account that allows the holder of the account to set aside a certain amount of money every year that is tax-sheltered.  Not only is the money that is deposited each year into the account tax deductable, but the earnings in the account also grow tax deferred until they are distributed.  Another advantage of an IRA is that one can have an IRA account even if they are also covered under another retirement plan.  However, individuals who are also covered by an employer-based plan may not be eligible to fully deduct their annual contributions to an IRA account.   

There are annual contribution limits to an IRA.  For 2010, an IRA holder can contribute up to $5,000, or their taxable compensation for the year, whichever is lesser.

Roth IRA

Much like a traditional IRA, a Roth IRA is a retirement savings fund with tax advantages.  What makes a Roth IRA different than a traditional IRA is that annual contributions to a Roth IRA are nondeductible.  The advantage of a Roth IRA is that in most cases the earnings accrued and distributions received from the account are entirely tax-free.  As with the traditional IRA, the maximum contribution level allowed by a Roth IRA account holder in 2010 is the lesser of $5,000 or the taxable compensation for the year.

Employer-Sponsored Plans

There are several different types of employer-sponsored retirement plans that have both a salary deferral component and an employer contribution component to each of them.  Some of the more popular plans include the 401(k), the 403(b) and the SIMPLE plan.  These plans allow the employee to defer a percentage of their monthly compensation to a retirement fund.  The employer also makes a contribution to the retirement fund on the employee’s behalf.  Both the contributions of the employer and the employee are not taxed until the funds are withdrawn. 
By electing to defer compensation under an employer-sponsored program, the employee is able to reduce their taxable income each year.  Also, because the maximum contributions limits to employer-sponsored plans are much larger than what is allowed under other plans, the tax benefits associated with an employer-sponsored plan are more significant.  

If you are an individual who make substantial annual income or a small business owners offering a retirement plan to your employees, it is highly recommended that you have your individual situation analyzed by an experienced tax professional.  The tax attorneys and tax professionals at the Law Office of Stephen Moskowitz, LLP are skilled in analyzing which combination of retirement plans are right for you or your business.  Call us today at 1-800-829-3327 for your free consultation and find out how we might be able to save a great deal more on your taxes each year.

San Francisco CA – October 26, 2011 – The United States (“U.S.”) and Korean Governments have entered into SCIP to combat tax evasion in the partnering countries.  The agreement between the U.S. and South Korea will allow the IRS to obtain records from South Korea’s National Tax Service (NTS) to verify and compare information reported by South Korean Americans to both agencies.  The NTS is focused on monitoring illegal schemes by South Korean businesses and individuals that move funds abroad, avoid taxes offshore and participate in money laundering schemes.

The IRS is interested in the actions of U.S. taxpayers centered in South Korea, particularly South Korean investors, who invest money illegally through affiliates in other countries.  SCIP mandates that Foreign Bank Account Holders (“FBA”) properly report their assets.  Since 2009, South Korea has entered into information-sharing agreements with 14 regions and countries including the British Virgin Islands, Costa Rica, The Cayman Islands, Malaysia, Panama and, now, the United States. 

Woori Bank, the oldest continuously operating bank in Korea, in response to SCIP, will call upon tax attorney Steve Moskowitz to help South Koreans comply with disclosing overseas holdings to the IRS.  Two seminars addressing SCIP and IRS programs will be held at the Domain Hotel in Sunnyvale, CA on November 3, 2011 and the Walnut Creek Marriott Hotel in Walnut Creek, CA on November 4, 2011.

Mr. Moskowitz, with over three decades of experience in tax law will address The Report of Foreign Bank and Financial Accounts (“FBAR”) and a proven course of action, among other tax concerns for South Koreans.

“The IRS is targeting South Koreans living in the United States, who are suspected of tax evasion, and has every right to request financial information from the South Korean government regarding Korean-Americans living in the United States,” says Steve Moskowitz.  “This could include real estate records, bank account information, tax returns and other pertinent information.  Many South Koreans living in the United States are nervous because they may have an inheritance from parents, have amassed funds prior to immigrating to the United Sates or possess investment funds and are unsure about reporting these assets,” he adds.

Woori Bank is headquartered in Seoul, Korea and includes the former Commercial Bank of Korea, Hanil Bank and Peace Bank.  Steve Moskowitz is the founding partner of Moskowitz LLP, and routinely provides advice regarding Offshore Accounts, Amnesty Programs, Passive Foreign Investment Companies (“PFIC”), Qualified Electing Funds (“QEF”), market-to-market calculations, informational returns, compliance and all other tax issues.

California taxpayers who underreported their state income tax liabilities through the use of offshore entities have until October 31, 2011 to avoid criminal and civil (monetary) penalties and interest by participating in the California Voluntary Compliance Initiative 2.  Due to the information sharing agreement between the IRS and the states, precipitation may be especially vital for taxpayers who took part in the Federal Offshore Voluntary Disclosure Initiative in 2011 or the previous federal amnesty in 2009. 

Program Overview

The California Voluntary Compliance Initiative 2 is an amnesty program for taxpayers who have used “abusive tax avoidance transactions” or offshore financial arrangements.  An “abusive tax avoidance transaction” is defined as either a tax shelter, a reportable transaction that is not adequately disclosed, a listed transaction as defined under the tax code, a gross misstatement, or a transaction in which the California noneconomic substance transaction (NEST) penalty applies.  Further, there are additional amnesty penalties that may be assessed to non-participants.   

To participate in the program, the taxpayer must complete a Participation Agreement (which requires an admission of the intent to evade California taxes), attach appropriate tax forms, as needed, and pay all taxes and interest to the California Franchise Tax Board by October 31, 2011.  Payment plan options are available to those who qualify. 

Key Benefits of the Program

There are two major reasons taxpayers should seriously consider participating in the California Voluntary Compliance Initiative 2.  First, participants will greatly reduce their criminal exposure if they report their involvement in an offshore financial arrangement or an “abusive tax avoidance transaction.”  Secondly, participants may avoid many applicable penalties.  Those who choose not to participate in the California Voluntary Initiative 2 are subject to severe penalties ranging from 20% to 100% of the subject amount, depending on the nature of the underpayment, for a period of twelve years, yes, twelve years.  

Detriments to the Program

As tax attorneys, we are particularly concerned that taxpayers are required to make statements that could be deemed admissions of criminal intent in order to participate in the program.  We are also concerned that taxpayers may waive any rights to appeal determinations and/or contest specific penalties or tax implications should they arise from the filing of amended tax returns or otherwise by participating in the program.

Implications of the Federal and State Information Sharing Agreement

California and the Federal Government have an information sharing agreement whereby the parties report to each other all information they may have about the participants in their programs.  This means that Californians who participated in the Federal Offshore Voluntary Disclosure Initiative in 2011 or the 2009 program will be reported by the IRS to the California Franchise Tax Board.  Conversely, the California Franchise Tax Board will report all participants in the California Voluntary Disclosure Initiative 2 to the IRS.  Not only will they pass along identifying information but participants can expect that any “admissions” on forms that the taxpayer completed will be handed over as well.  Thus, in most cases, a taxpayer who participated in one government’s program is unwise not to participate in the other program.
 
If you are considering participating in the California Voluntary Disclosure 2 initiative, you should consult an experienced tax attorney first.  Remember, you only have an attorney-client privilege when you talk to an attorney.  Other tax professionals do not afford you this important benefit. 

Not all amnesty programs are right for every taxpayer and the facts of your particular situation should be analyzed by a tax attorney before you lift the veil on your situation for the government.  The skilled tax attorneys at the Law Offices of Stephen Moskowitz, LLP have helped countless clients decide whether to participate in this and other amnesty programs.  Call me at 1-888-829-3325 for your free attorney-client privileged consultation to see if the California Voluntary Disclosure Initiative 2 is right for you.  And don’t forget that the program expires October 31, 2011. 

The federal Offshore Voluntary Disclosure Initiative (OVDI) ended on September 9, 2011.  This means that taxpayers with unreported foreign bank accounts have to make some tough choices about how to proceed if they intend to voluntarily disclose those accounts to the IRS. 

2011 OVDI Recap

OVDI offered immunity from criminal liability for a taxpayer’s noncompliance with the Report of Foreign Bank and Financial Accounts (commonly known as “FBAR”) in exchange for automatic penalties of 25 percent, 12.5 percent or 5 percent of the amount held in the foreign account depending the taxpayer’s particular situation.  While the IRS did not extend the OVDI deadline beyond September 9, 2011, taxpayers with undisclosed foreign bank accounts can still apply for relief under the Traditional Voluntary Disclosure Program at any time. 

Traditional Voluntary Disclosure Program

For decades, the IRS has followed essentially the same general policy regarding criminal and civil penalties for failing to disclose a foreign bank account pursuant to FBAR.  With regard to the criminal side, that policy holds that the voluntary disclosure of a foreign bank account will not itself guarantee criminal immunity but will be considered, along with all the other factors in the case, in deciding whether to recommend criminal prosecution.  In the overwhelming majority of cases, the IRS does not criminally prosecute taxpayers who willingly disclose information about their foreign account before they are discovered by the IRS.

Criminal penalties aside, the IRS can levy a wide array of civil penalties under the Traditional Voluntary Disclosure Program.  For instance, a taxpayer who comes forward for negligently failing to disclose his or her offshore account may be responsible for paying an assessment of $10,000 for each tax year beginning in 2005.  Additionally, the IRS can impose an assessment as high as the greater of $100,000 or 50 percent of the value of the undisclosed foreign account per violation and per year against a taxpayer who willfully fails to disclose his or her foreign bank account. 

Benefits of the Traditional Voluntary Disclosure Program

The fact that there is no formal OVDI-like penalty schedule under the Traditional Voluntary Disclosure Program may actually benefit a disclosing taxpayer.  Because there are no set penalties under the Traditional Voluntary Disclosure Program, the IRS must review the taxpayer’s particular situation and levy what they consider to be the appropriate tax assessments allowed under the FBAR.  If the taxpayer disagrees with this outcome and refuses to pay the FBAR assessment, the IRS must file a civil action in Federal District Court and pursue a judgment to recover from the taxpayer.  The IRS wants to avoid litigation because it is time consuming and expensive so they may be willing to offer a reasonable settlement following a refusal to pay an assessment.  Additionally, a recent case out of the Eastern District of Virginia (United States v. Williams found here: http://docs.justia.com/cases/federal/district-courts/virginia/vaedce/1:2009cv00437/241710/55/0.pdf) illustrates that that the IRS may encounter considerable resistance from the courts in pursuing the current FBAR assessment formula related to the willful failure to disclose a foreign bank account.  This case might also persuade the IRS to offer a more favorable assessment or settlement, or it might encourage the IRS to charge more people criminally.  

Drawbacks of the Traditional Voluntary Disclosure Program

The Traditional Voluntary Disclosure Program lacks the predictability of no criminal prosecution and civil penalties found in the 2011 OVDI.   However, with the right combination of strategy, experience and representation, the IRS may offer settlement packages that are far more attractive than the OVDI program. 

It is vital that you seek advice from an experienced tax attorney before disclosing a foreign bank account through the Traditional Voluntary Disclosure Program.  Every client’s facts and circumstances are unique and there are no easy cases in this post-OVDI world.  Call the Law Offices of Stephen Moskowitz, LLP today and get a team of experienced attorneys to advise and represent you.