Category: Tax Planning

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

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 Rev
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

IRS warns people about a COVID-related text message scam

The IRS  is warning people to be aware of a new text message scam.

The thief’s goal is to trick people into revealing bank account information under the guise of receiving the $1,200 Economic Impact Payment.

Here’s how this scam works: People get a text message saying they have “received a direct deposit of $1,200 from COVID-19 TREAS FUND. Further action is required to accept this payment… Continue here to accept this payment …” The text includes a link to a phishing web address.

This fake link appears to come from a state agency or relief organization. It takes people to a fake website that looks like the IRS.gov Get My Payment website.  If people visit the fake website and enter thei

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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.[1]  In a recent interview between Kaepernick’s attorney, Mark Geragos and