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Tax practitioners have previously lacked a dedicated resource to call their own. For those intrepid souls, we offer TaxBlawg, a forum of tax talk for tax pros.
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- Posts by Kevin F. SweeneyShareholder
Kevin Sweeney is an experienced tax attorney and former federal prosecutor who specializes in defending clients in civil and criminal tax controversy and litigation matters. He focuses on high-stakes IRS audits, civil tax ...
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 ...