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Tag: Criminal Tax Investigations & Prosecutions

IRS Criminal Investigation Agents Are Investigating Malta Pension Plans

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 participants in the Malta Pension

The State of the Tax Whistleblower Law

By Usman Mohammad and Ashley Morales ABA Tax Times June 2023 Internal Revenue Code section 7623(b) provides mandatory awards to whistleblowers who provide information to the IRS that results in the collection of additional tax, interest, penalties or fines from corporations, high net worth individuals, and other entities. The statute

Christopher Ferguson Moderates A Panel Titled “Employee Retention Credit Audits And Investigations – The Tsunami Is Coming” At The 2023 NYU Tax Controversy Forum

On June 8, 2023, Christopher Ferguson moderates a panel titled “Employee Retention Credit Audits and Investigations – The Tsunami is Coming” at the 2023 NYU Tax Controversy Forum. Description: ​Claims for Employee Retention Credits (“ERCs”) have proliferated exponentially. Almost everyone has seen a commercial or received a text or email