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.
Category: Tax Planning
U.S. INDIVIDUALS ALLEGED TAX CRIMINALS BY DENMARK
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
(b) To whom applicable. This section applies to any practitioner who, within 5 years prior to the date that a show-cause order under this section’s expedited suspension procedures is served:
(1) Has had a license to practice as an attorney, certified public accountant, or actuary suspended or revoked for cause (not including failure to pay a professional licensing fee) by any authority or court, agency, body, or board described in § 10.51(a)(10).
How much did Colin Kaepernick actually receive from his “opting out” of the contract with the San Francisco Giants following the 2016 season and the recent Collective Bargaining Agreement, (CBA), with the NFL.
In a recent interview between Kaepernick’s attorney, Mark Geragos and CNN’s Ana Cabrera, Geragos clarified that the disagreement was resolved through the CBA with a Confidentiality Agreement for a undisclosed amount with speculation between $20 Million and $100 Million. 
However, no one is saying anything about what the final amount was agreed upon. Lets put forth a few scenarios with the possibility that one could be close to the negotiating amount.
Here is what is known, the NFL possibly pa