In recent years, U.S. taxpayers have engaged in “Malta pension plans,” utilizing these arrangements to contribute appreciated assets and claim tax exemptions under the U.S.-Malta tax treaty. Nevertheless, the U.S. government has responded with measures, including the Competent Authority Arrangement (CAA) and proposed regulations, aiming to restrict treaty benefits due to suspected misuse and potential

FTX is embroiled in a $24 billion tax dispute with the Internal Revenue Service (IRS) in its bankruptcy case. The IRS claims FTX owes this amount in unpaid taxes, but FTX says the claim has “no relation to reality” (Law360, 2023). An estimation hearing has been ordered by the bankruptcy judge to determine the validity

The IRS recently issued a press release regarding its “continuous efforts to combat dubious Employee Retention Credit (ERC) claims” to announce an initial round of over 20,000 notification letters of disallowed ERC claims. This initial round of notices is addressing two “problem areas” the Service has identified in their ongoing review of ERC claims: 1)

In November 2023, Gray Reed Tax Partners Joshua Smeltzer and Matthew Roberts authored an article titled “Where Have All the Theft Losses Gone?” published in Taxes: The Tax Magazine.

The article discusses whether taxpayers can deduct theft losses on their tax returns for 2018-2025 after new limitations were set by the 2017 Tax Cuts

The top charge in the federal election interference indictment against former President Trump alleges a conspiracy to defraud the government by impairing, obstructing and defeating the lawful federal governmental function of certifying presidential election results. That nontax conspiracy charge is based on the same precedent that undergirds many tax conspiracy charges.

On September 4, 2023

United States citizens and residents are often not aware of the myriad of foreign information return filing obligations that exist under federal tax laws.  For example, buried within the Code are reporting obligations associated with the receipt of a foreign gift and participation and ownership in foreign trusts.  The failure to file these information returns—referred

The tax community is currently embroiled in a heated debate over proposed IRS guidelines concerning timing provisions, the broad scope of individuals eligible to approve penalties and exemptions related to automated penalty calculations.

At the heart of the controversy lies Section 6751(b), which mandates that the immediate supervisor of a revenue agent must personally provide

It is big news right now that the US government is facing partial closure.  The partisan politics in Washington are going to affect most Americans whether they expect it or not.  My list of the tax implications to the shut down is:

  1. Approximately 90 percent of IRS employees are not at work today.  If you