Category: Tax Planning

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

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

IRS warns people about a COVID-related text message scam

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: Pe

Kaepernick’s NFL Settlement Amount

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 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. [2]

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

This Year You are Preparing Your Own Tax Return

So, this year you are preparing your own tax return, no need for a CPAs, Enrolled Agent or Tax Attorney…great! But have you thought about “FBAR” and your 2018 tax return!!! You might ask, do I have to worry about this FBAR quagmire if I have never been outside of the United States? YES