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 […]

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 specifying the annual budget and expenditures of the United […]

If you have not learned from the Panama Papers debacle, then listen up to the newly enacted Panama laws for declaration of the ultimate Beneficial Owners’ reporting requirements.  Penalties are extremely harsh! The resident agent will be sanctioned with fines ranging from $1,000  to $50,000 for each legal person whose information is not registered or […]

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 […]

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, […]

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. […]

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 […]

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 […]

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 […]

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 “with-without” that illustrates the vanishing of dividend payments. […]