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Tag: Voluntary Disclosures

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

Caroline D. Ciraolo Delivers A Keynote Address Titled “The Role of U.S. Department of Justice, Tax Division in International Criminal Tax Enforcement” At The 40th Cambridge International Symposium on Economic Crime

On Tuesday, September 5th, 2023, Caroline D. Ciraolo presents a keynote address titled “The Role of U.S. Department of Justice, Tax Division in International Criminal Tax Enforcement” at the upcoming 40th International Symposium on Economic Crime, Jesus College, University of Cambridge. Date: 8:00am BST (U.K. Time) on Tuesday September 5th, 2023. A full

Caroline Ciraolo Appears On Tax Chat! Series On Transforming Tax Administration Entitled “IRS Penalty Policy and Practice” At The Center for Taxpayer Rights

On August 15th, 2023, Caroline Ciraolo participates in a webinar panel titled “IRS Penalty Policy and Practice” as part of a webinar series titled “Transforming Tax Administration” presented by Center for Taxpayer Rights. Description: Center for Taxpayer Rights presents a series of webinars from March 23, 2023 through August 31,

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