The IRS has now issued their opinion on their understanding of the meaning of pension fund for purposes of the United States–Malta income tax treaty (Treaty). The competent authorities, CA, have entered into this agreement on December 23, 2021, after becoming aware that U.S. taxpayers with no connection to Malta were misconstruing the pension provisions of the Treaty to avoid income tax on the earnings of, and distributions from, personal retirement schemes established in Malta.

U.S. and Malta competent authorities’ understanding that (except in the case of a qualified rollover from a pension fund in the same country) a fund, scheme, or arrangement is not operated principally to provide pension or retirement benefits if it allows participants to cont

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Some U.S. citizens and residents are relying on an interpretation of the U.S.-Malta Income Tax Treaty (Treaty) to take the position that they may contribute appreciated property tax-free to certain Maltese pension plans and that there are also no tax consequences when the plan sells the assets and d
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COVID-19 FRAUD:  Federal Bureau of Investigation                

The Federal Bureau of Investigation and the Small Business Administration Office of Inspector General initiated an investigation into the submission on behalf of five businesses of fraudulent Paycheck Protection Program (PPP) loan applications for approximately $800,000 each.  BSA data played an integral role in identifying numerous leads on subjects associated with the fraud and to identify the flow of fraudulent funds.  The BSA records also helped uncover a separate scheme by the main subjects of the investigation involving fraudulent auto loans.

Authorities seized a vehicle valued at $125,000, jewelry, over $120,000 in cash, and over $3 million fr

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U.S. INDIVIDUALS ALLEGED TAX CRIMINALS BY DENMARK Part III. SETTLEMENT REACHED WITH NORTH CHANNEL BANK In August of 2020, the North Channel Bank offered an unusual statement in their website addressing the indictment proceedings of the Kingdom of Denmark against North Channel Bank. Below are excerpt
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U.S. INDIVIDUALS ALLEGED TAX CRIMINALS BY DENMARK

Part II.

INDIVIDUALS AND COMPANIES IDENTIFIED.

As discussed in Part I. of this continuing Article, Denmark is vigorously looking for the 6 individuals who have allegedly defrauded the Government of Denmark of more than $2.1 billion via a dividend-tax scam.  Three of the 6 individuals are US citizens and as the year-long investigation continues, more individuals and entities will be named.  

The German lender, North Channel Bank, is now added to the list of those committing economic malfeasance and 3 of the above-mentioned individuals were/are owners of North Channel Bank.  Denmark continues to name their mastermind behind this scheme as the hedge fund f

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On April 13, 2021, the Danish State Prosecutor for Serious Economic and International Crime publicly named and charged 3 U.S. residents and 3 British residents with defrauding the Danish tax authorities of more than US$176 million in a sham trading scheme called “cum-ex” which is Latin meaning
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Health Care Consultant Pleads Guilty to Fraud and Tax Evasion

Sonja Emery, according to Court Records, used aliases and addresses including “Sonja Lee Robinson,” “Sonjalee Emery-Robinson,” and “Sonjalee Emery,” residing in Georgia, New Jersey, New York, and California.  From 2011 through 2018, Emery falsely represented her professional status, educational background, and work experience to secure and maintain highly paid consulting positions in the health-care industry.

She falsely claimed to have:

A nursing diploma from a school she never attended. She also falsely claimed to be a Registered Nurse licensed in New York, Georgia, Connecticut, and California Provided employers with licensure numbers that belonged to other people. In fact, she never was a Re
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Robert F. Smith Background and Non-Prosecution Agreement INTRODUCTION: Mr. Smith in 2020, at the age of 57, entered into a Non-Prosecution Agreement, NPA, with the IRS.   Let’s look at what I believe happened to Mr. Smith to cause his personal and professional life to intersect with potential