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Malta Pension Plan Being Investigated by IRS Criminal Investigation Division

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Malta Pension Plan Being Investigated by IRS Criminal Investigation Division

2 July, 2023

...development last week, IRS Criminal Investigation (IRS-CI) Special Agents began visiting taxpayers and advisors who have participated in, or advised on, Malta Pension Plans. IRS-CI agents are issuing summons to...

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National Taxpayer Advocate Fights for FTA Penalty Relief from the IRS

28 June, 2023

...taxpayers or taxpayers who paid for professional assistance received penalty abatements just for asking, while the overwhelming majority of taxpayers who do not know the IRS is willing to abate...

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How to Avoid Employee Retention Credit (ERC) Scams

21 June, 2023

...information about eligibility or how the credit is calculated, the IRS said. Properly Claiming the ERC Eligible taxpayers can claim the ERC on an original or amended employment tax return...

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Watch Out: Malta Pension Plans Become Listed Transaction

12 June, 2023

...the IRS will take the position that taxpayers are not entitled to the purported tax benefits. A tax attorney with experience in the Malta plans can assist taxpayers in compliance....

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Beware Expected Employee Retention Credit (ERC) Audits

9 June, 2023

...taxpayer makes an unintentional mistake on their tax return. Interest is charged on any amount of tax that is owed to the IRS. If a taxpayer is found to have...

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Parag Patel Esq. Speaks at Annual Convention of New Jersey Society of Certified Public Accountants

5 June, 2023

...Description: Hot Topics in Tax Controversy With new funding, the IRS has ramped up enforcement, and all tax professionals must be familiar with the latest strategies in audit and tax...

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Parag Patel Esq. Speaks to New Jersey Society of Certified Public Accountants (NJCPA) Nonprofit Interest Group

1 June, 2023

...apply to tax-exempt, not-for-profit entities. The program covered new tax court decisions, recent IRS publications, the latest tax legislation that will impact tax-exempt entities, IRS tax-exempt procedures, and other issues....

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What is a Mark-to-Market (MTM) election for a Passive Foreign Investment Company (PFIC)?

11 May, 2023

...value at the end of each taxable year, recognizing any gain or loss for that year. Under the mark-to-market election, the taxpayer is required to include in their taxable income...

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Comments on IRS Form 3520 to Report Foreign Gifts

1 May, 2023

...IRS is currently assessing maximum penalties for late and amended Forms 3520, which is not the case for most other international reporting tax forms. As a result, unsuspecting U.S. person...

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REPORTING FOREIGN ASSETS & ACTIVITIES: REQUIREMENTS AND CHALLENGES: Complimentary CPE Presentation

9 April, 2023

...joined the firm in 2017 and specializes in international taxation and planning strategies. Darko’s tax practice is consumed by international tax matters including U.S. tax aspects of international business such...

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Tax Court Rules IRS Cannot Assess or Collect Form 5471 Penalties

6 April, 2023

...recording a tax liability on the IRS’s records for a taxpayer. After assessment and failure to pay, the IRS can enforce the collection of tax, penalties and interest by asserting a lien...

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Foreign Gift Received: Form 3520 Penalties Eliminated in New Court Case

3 April, 2023

...and Bittner cases may indicate a move by the IRS and Tax Division of the DOJ to show more leniency towards taxpayers who report failures to file international informational returns...

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