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
Diamonds in the Rough Notes: The Importance of Obtaining Informal Notes of Witness Statements
By Daniel Cady Davidson New York State Bar Association Journal August 16, 2023 For the trial attorney, familiarity with prosecution witnesses’ statements is fundamental to effective trial preparation. A recent federal health care fraud case in Texas (U.S. v. Swiencinski) underscores just how critical it
When Past Is Prologue: Why the Justice Department’s Revised Corporate Enforcement Policies May Create More Problems Than They Solve
By Sharon McCarthy and Christopher Ferguson American Bar Association Criminal Justice Section, The White Collar Crime Committee Newsletter Summer/Fall 2023 Edition We are all familiar with the aphorism that those who forget history are condemned to repeat it. The Department of Justice’s (“DOJ” or the
IRS Criminal Probe Spells Uncertainty For Malta Pension Plans
An Inconvenient Truth About Remote Work
Revisions to Form 14457 Could Facilitate Crypto Disclosures
IRS’s Efforts in Providing Cryptoasset Guidance are Clear
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