IRS Aggressively Starts New Criminal Investigations

The IRS announced last week in a press release that it is taking “swift and aggressive action” to strengthen enforcement efforts against high-income individuals as it uses the new budget funding it recently received.

Recent enforcement efforts include closing about 175 delinquent tax cases for millionaires yielding $38 million and intensifying criminal investigation work to crack down on millionaires who do not file tax returns.

Specifically, the IRS identified about 100 high-income people claiming benefits in Puerto Rico without meeting certain requirements, with many of those cases expected to be taken up by the Criminal Investigation division.

The IRS is also escalating enforcement efforts around unlawful offshore tactics, specifically targeting Maltese personal pension plan schemes. In June, the IRS and Treasury issued proposed rules that define Maltese personal retirement schemes used to avoid U.S. taxes as “listed transactions”. 

The IRS stated that it is working to identify taxpayers that are improperly using Malta-U.S. Treaty rules to claim exemptions improperly. The IRS said it will “forcefully find tax avoiders who leverage these offshore [Malta pension plan] schemes.”

We have learned that the IRS recently served up to 100 criminal summonses to alleged Malta pension plan advisors and nearly 200 criminal summonses to alleged Malta pension plan participants.

Although an IRS Summons (Form 2039) is not the same as a court summons, it is serious and should not be ignored.  If you receive a summons, you should consult an experienced tax attorney immediately.

Patel Law Offices offers a strategy session to discuss how to resolve your legal problem. Conveniently schedule online today with our online scheduler and questionnaire.