Kostelanetz News Brief: In Landmark Case, Justices to Decide Constitutionality of Mandatory Repatriation Tax
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 al. v. United States, Case
UPDATE: Criminal Investigation Of Malta Pensions Heats Up As IRS Issues Flurry Of Summonses
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 otherwise allowed under the U.S.-Malta
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
Michael Sardar Quoted In Yahoo Finance In An Article Entitled “IRS gets major power to request private tax info after Supreme Court decision”
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. The article notes: Last month,
John D. Fort Participates In A Summit Titled “Robots and Robbers: Financial Crime Technology Summit” At The Financial Crime Academy
On July 11, 2023, Don Fort provides opening remarks and will lead a panel of experts to open the summit titled “Robots and Robbers: Financial Crime Technology Summit,” a three-day virtual financial crime summit presented by The Financial Crime Academy. Description: Technology has made great advancements in the financial world,
The State of the Tax Whistleblower Law
Caroline D. Ciraolo Presents On A Panel Titled “Coming in from the Cold: The Future of Voluntary Disclosures” For The CPA Academy
On June 28, 2023, Caroline D. Ciraolo participates in a panel titled “Coming in from the Cold: The Future of Voluntary Disclosures” for the CPA Academy. Description: For more than 70 years, the IRS has had a voluntary disclosure policy designed to encourage taxpayers to come in from the cold
Sharon L. McCarthy Participates In A Panel Titled “Flipping The Script: Putting The Government On Defense At Trial” At The NYU Tax Controversy Forum
On June 9, 2023, Sharon L. McCarthy participates in a panel titled “Flipping The Script: Putting The Government On Defense At Trial” at the NYU Tax Controversy Forum. Description: Despite best efforts to reach alternative resolution, litigation is often the best or only option. This panel discusses effective trial strategies
Don Fort Moderates A Panel Titled “IRS Criminal Investigation Division Enforcement Update” At The NYU Tax Controversy Forum
On June 9, 2023, Don Fort moderates a panel titled “IRS Criminal Investigation Division Enforcement Update” at the NYU Tax Controversy Forum. Description: With the increase in the IRS enforcement budget coupled with the recent focus on fraud enforcement, tax professionals anticipate a surge in criminal tax investigations and prosecutions.