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Tag: Estate and Tax Planning

IRS to Target Partnership Basis Shifting Abuses

On the heels of a significant boost in funding brought by the August 2022 passage of the Inflation Reduction Act (“IRA”), the IRS this week announced new efforts to combat what it sees as abusive transactions and strategies utilized by businesses that are taxed as partnerships. This is another IRS

ChatGPT for Legal and Tax Professionals

By Garrett L. Brodeur, Grace Hall, and Ella Tynch CPA Journal September 2023 Since the introduction of ChatGPT in November 2022, artificial intelligence (AI) has taken the legal and accounting professions by storm. The use of AI in legal proceedings has already made headlines and research now suggests that most legal

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

An Inconvenient Truth About Remote Work

By Stephen A. Josey CPA Journal May/June 2023 The “convenience of the employer” rule for sourcing income to a particular state is anything but convenient for tri-state taxpayers. Most states that levy an income tax look to where an employee’s work is performed in determining whether their income is taxable