International Tax

Potentially abusive use of the US-Malta tax treaty

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 distributes proceeds to the U.S. taxpayer. Ordinarily, the gain would be recognized upon disposition of the plan’s assets and distributions of the proceeds. The IRS is evaluating the issue to determine the validity of these arrangements and whether Treaty benefits should be available in such instances and may challenge the associated tax treatment.

FinCEN Report to U.S. Senate’s Committee on Banking, Housing and Urban Affairs.

United States Senate on May 2019 Issue: Eliminating anonymous shell corporations by collecting beneficial ownership information in order to preserve our national security and protect our people from harm. I. THE MERCHANT OF DEATH A Russian arms dealer nicknamed the “The Merchant of Death,

U.S. Treasury’s Financial Crimes Enforcement Network, FinCEN.

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 P

U.S. Individuals AllegedTax Criminals Denmark

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 excerpts of this statement:

“Over the past three years, under the current management, the bank has cooperated with the investigating authorities in a very transparent manner and supported the investigations.” The business organization under the Bank’s name was used to facilitate”…the illegal cum-ex business at the expense of Denmark and Belgium was already ceased by the current management in early 2017.” The Bank did act quickly to remove any employees where

U.S. Individuals Alleged Tax Criminals by Denmark

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

U.S. Individuals Alleged Tax Criminals by Denmark

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 “with-without” that illustrates the vanishing of dividend payments. In summary, this dividend scheme is believed to involve the trading of company shares rapidly around a syndicate of banks, investors, and hedge funds to suggest numerous owners, each entitled to a tax rebate from the Danish Government which is fraudulent and patently illegal.

Earlier, in January of 2021, 2 UK citizens were charged in this illegal scheme that brings in a current total of 8 non-Danish individuals. Of

Individual Voluntarily Giving up Their United States Citizenship

This listing contains the name of each individual voluntarily giving up their United States citizenship with respect to whom the Secretary received information during the quarter ending December 31, 2020. For purposes of this listing, long-term residents are treated as if they were citizens of the

Health Care Consultant Pleads Guilty to Fraud and Tax Evasion

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 throug

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 Criminal Prosecution with the United States Government. Let’s also see what could have been done differently to head off such a horrible outcome to his reputation, his freedom, and a lifelong stain on his legacy.

Finally, let’s see if this is now the end of Mr. Smith’s criminal and civil problems with the successful negotiation of this NPA.

PART I.

Background

Operating on the “DARKNET” Brings a penalty of $209,144,554

OPERATING ON THE “DARKNET” BRINGS A PENALTY OF $209,144,554. Larry Dean Harmon is a U.S. person residing in Akron, was the creator, administrator, and primary operator of Grams, a darknet website that operated on the onion router (Tor) network and advertised itself as the “Google of the Darkwe