Earlier this year, the Internal Revenue Service (IRS) included various forms of abusive trust schemes on its 2023 “Dirty Dozen” list, and it followed this up with the publication of an extensive Abusive Trust Tax Evasion Schemes Toolkit outlining what it considers to be an abusive trust arrangement for federal tax compliance purposes. Now, following an investigation conducted by IRS Criminal Investigation (IRS CI), the U.S. Department of Justice (DOJ) has announced charges against two individuals who are accused of promoting abusive trust schemes that “resulted in tens of millions of dollars in federal income taxes not being paid to the IRS.”Read More

Due to widespread fraud during the COVID-19 pandemic, federal authorities are continuing to heavily scrutinize Paycheck Protection Program (PPP) loan applicants and businesses that have claimed the Employee Retention Credit (ERC). Allegations of PPP fraud and ERC fraud can pose substantial risks—including the risk of criminal prosecution in some cases. As a result, all entities and individuals targeted in pandemic fraud investigations need to take a proactive approach to their defense, and this starts with engaging a Washington D.C. tax lawyer who has specific experience handling these high-stakes cases.Read More

The Employee Retention Credit (ERC) program is one of several federal relief programs that saw high levels of fraud during the COVID-19 pandemic. While the ERC is still available for eligible businesses to claim retroactively, the Internal Revenue Service (IRS) and other federal authorities are actively targeting ERC fraud in 2023.Read More

In 2011, the U.S.-Malta Tax Treaty started a gold rush of sorts. The treaty’s language arguably (and unintentionally) allowed U.S. taxpayers to open personal retirement plans in Malta, contribute appreciated assets, and then systematically take structured distributions without incurring federal tax liability on the plan’s interest or principal. This led to many taxpayers opening Maltese pension plans—with some avoiding tens of millions of dollars in federal income tax liability.Read More