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- Posts by John Kirbo
Senior CounselJohn Kirbo is a Senior Counsel in our tax controversy practice in Atlanta. John primarily represents clients before the Tax Court, Federal District Court, and the Internal Revenue Service.
John has a background in business ...
Recently, the IRS has been devoting substantial resources to its investigation of Malta Pension Plans. Just this month, the IRS Criminal Investigation division served summonses on multiple entities and persons who it believes were involved with such plans, and has proposed making the transaction a “listed” transaction. Either action would be noteworthy, but that combined activity tells a story of deep IRS scrutiny. This article discusses that activity, and provides some high-level options for affected taxpayers.
The Latest Listed Transaction: the Maltese Pension
On June ...