Category: Tax Planning

FBAR now has a close cousin named CTA

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.

Recently enacted legislation termed “CTA” that may affect your tax planning

Recently enacted legislation termed “CTA” may affect your tax planning. The recently enacted legislation is part of the National Defense Authorization Act (NDAA) enacted by Congress on January 1, 2021, through the override of a presidential veto. The NDAA is a series of federal laws primarily sp

Warning to Individuals with Malta Personal Retirements

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 conn

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 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

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 excerpt

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

Expedited suspension from practice before the IRS

10.82 Expedited suspension (a) When applicable. Whenever the Commissioner, or delegate, determines that a practitioner is described in paragraph (b) of this section, the expedited procedures described in this section may be used to suspend the practitioner from practice before the Internal Revenue Service.

(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).

(2) Ha

Recovery Rebate Credit/Economic Impact Payment.

For this year, 2020, there are some key items to consider involving credits, deductions, and refunds: Recovery Rebate Credit/Economic Impact Payment. Taxpayers who received an Economic Impact Payment should keep their Notice 1444, Your Economic Impact Payment, with their 2020 tax records. You may be