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Articles by Caroline Ciraolo
How Tax Pros Can Shift From Government to Private Sector Work Original
With the reduction in the federal workforce, more tax professionals are transitioning from public service to the private sector and bringing a wealth of knowledge that will benefit their new employers, colleagues, and clients. Many of these professionals are entering private practice with limited, if any, experience working for a private firm. While legal knowledge can transition, representing individuals and entities and developing business require a different set of skills.
IRS Doesn’t Have It Easy With Malta Pension Enforcement Efforts
High-net-worth US taxpayers, working with professional advisers, have transferred assets into personal retirement plans established in Malta to limit and potentially eliminate tax on distributions. These so-called Malta pension plans rely on a specific interpretation of the US-Malta tax treaty. This interpretation hasn’t been tested in the courts, but the IRS expressly rejected it in its clarification of the treaty in December 2021.
IRS Doesn’t Have It Easy With Malta Pension Enforcement Efforts
High-net-worth US taxpayers, working with professional advisers, have transferred assets into personal retirement plans established in Malta to limit and potentially eliminate tax on distributions. These so-called Malta pension plans rely on a specific interpretation of the US-Malta tax treaty. This interpretation hasn’t been tested in the courts, but the IRS expressly rejected it in its clarification of the treaty in December 2021.
IRS Criminal Probe Spells Uncertainty For Malta Pension Plans
By Michael Sardar, Don Fort and Caroline Ciraolo (July 28, 2023, 4:21 PM EDT) -- Malta pension plan arrangements under the U.S.-Malta income tax treaty have been a focus of the Internal Revenue Service and U.S. Department of the Treasury for more than two years.... Law360 is on it, so you are, too. A Law360 subscription puts you at the center of fast-moving legal issues, trends and developments so you can act with speed and confidence.
Ciraolo: Criminal tax case against Trump unlikely
We are a long way from any significant action being taken. The New York Times laid out an explosive case last week that Donald Trump and some of his family members schemed for decades to evade tax laws. The opening paragraphs read like a formal indictment.
Ciraolo: Criminal tax case against Trump unlikely
We are a long way from any significant action being taken. The New York Times laid out an explosive case last week that Donald Trump and some of his family members schemed for decades to evade tax laws. The opening paragraphs read like a formal indictment.
Opinion | We’re a long way from a successful civil or criminal tax case against the Trumps
The New York Times laid out an explosive case last week that Donald Trump and some of his family members schemed for decades to evade tax laws. The opening paragraphs read like a formal indictment from a very confident prosecutor.
The IRS is taking off its velvet gloves for offshore holdings
Ferreting out people who want to hide their assets and income overseas is nothing new for the Internal Revenue Service. And for roughly nine years, the agency has sponsored programs tailored to those taxpayers who were prepared to come forward and disclose their unreported foreign assets and income in exchange for reduced penalties and the promise that they would not be prosecuted. These programs have had a tremendously successful run.
The IRS is taking off its velvet gloves for offshore holdings
Ferreting out people who want to hide their assets and income overseas is nothing new for the Internal Revenue Service. And for roughly nine years, the agency has sponsored programs tailored to those taxpayers who were prepared to come forward and disclose their unreported foreign assets and income in exchange for reduced penalties and the promise that they would not be prosecuted. These programs have had a tremendously successful run.
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