Foreign Bank Account Reporting, commonly known as FBAR now has a close cousin named CTA.

CTA is being created as of the beginning of the year 2021 and named the Corporate Transparency Act, to flush out Beneficial owners of Foreign Entities such as Corporations, LLC, and others where ownership is 25% as well as other criteria that includes tax fraud.

We will have a series of articles on CTA and the development as it applies to U.S. Citizens owning foreign assets and foreign entities. Please mark your calendar for upcoming information.

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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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,” who sold weapons to a terrorist organization intent on killing Americans. Executives from a supposed investment group that perpetrated a Ponzi scheme that defrauded more than 8,000 investors, most of them elderly, of over $1 billion. A complex nationwide criminal network that distributed oxycodone by flying young girls and other couriers carrying pills all over the United States. A New York company that wa

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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