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Tag: Internal Investigations

IRS Doesn’t Have It Easy With Malta Pension Enforcement Efforts

By Caroline Ciraolo, Don Fort, and Ian Weinstock  Bloomberg Tax August 28, 2023 High-net-worth US taxpayers, working with professional advisers, have transferred assets into personal retirement plans established in Malta to limit and potentially eliminate tax on distributions. These so-called Malta pension plans rely on a specific interpretation of the

IRS Criminal Probe Spells Uncertainty For Malta Pension Plans

By Michael Sardar, Don Fort, and Caroline Ciraolo Law360 July 28, 2023 Malta pension plan arrangements under the U.S.-Malta income tax treaty have been a focus of the Internal Revenue Service and U.S. Department of the Treasury for more than two years. That focus intensified recently as special agents from

Calling For Backup: When Do You (Or Your Clients) Need To Bring In Counsel?

By Caroline D. Ciraolo EA Journal September/October 2021, Vol.39 No.5 Tax controversy practitioners include various professionals with diverse experience and expertise. From tax return preparers to certified public accountants (CPAs) and enrolled agents (EAs) to tax attorneys, a client has many options in seeking advice from those authorized to practice