The Internal Revenue Service (“IRS”) announced its plan to pursue criminal investigations into potential abuses of Puerto Rico’s Act 20/22/60 tax incentive programs. In a July 14, 2023, release, the IRS revealed that “[t]hanks to Inflation Reduction Act resources,” it has begun a criminal crackdown on Act 20/22/60
In a case with far-reaching implications for tax jurisprudence, the U.S. Supreme Court will decide whether the controversial mandatory repatriation tax (MRT), created by the 2017 Tax Cuts and Jobs Act (TCJA), is unconstitutional under the 16th Amendment. The case is Charles G. Moore et
As reported in our last news alert, the IRS is moving aggressively to investigate Malta Pension Plans. This is after naming Malta Pension Plans to the IRS’s Dirty Dozen (its annual list of abusive transactions), issuing a Competent Authority Arrangement walking back the tax benefits
By Garrett L. Brodeur Tax Notes Federal July 3, 2023 In a recent Letter to the Editor, Garrett L. Brodeur noted that several recent informal guidance documents on the tax treatment of cryptoassets suggest that the IRS is striving to provide meaningful direction, even under
Malta Pension Plan arrangements under the United States-Malta Income Tax Treaty are a top enforcement priority of the IRS, finding their way onto the annual Dirty Dozen list. Yesterday, the IRS intensified its efforts as Special Agents from IRS Criminal Investigation (IRS-CI) descended on numerous
The New York State Bar Association (NYSBA) Tax Section published Report No. 1478 on June 18, 2023 to provide comments on the IRS’s recent proposal (in Notice 2023-27) to tax certain NFTs as “collectibles” under section 408 of the Internal Revenue Code. As a member
Michael Sardar was quoted in a recent article in Yahoo Finance entitled “IRS gets major power to request private tax info after Supreme Court decision,” published on June 11, 2023. The article discusses the ramifications of Polselli v. International Revenue Service on taxpayer and third-party privacy.
Garrett L. Brodeur was quoted in a recent article in Tax Notes entitled “Crypto Reg Delay Ruffles Lawmakers,” published on June 15, 2023. The article discusses the Treasury’s recent delay in issuing proposed cryptocurrency regulations. The article notes: Treasury is taking more time than usual
