In an article published in Accounting Today on July 25, 2023, Atlanta-based Shareholder Tom Cullinan, Philadelphia-based Shareholder Kevin Sweeney and Atlanta-based Senior Counsel John Kirbo discuss how the Internal Revenue Service is under tremendous pressure to justify the funding increases it has received from Congress. Their article outlines how they expect the IRS to deploy much of the additional funding earmarked for enforcement in the high wealth space, and mainly on promoted transactions that the IRS finds abusive. One of the first to focus on will be the Malta pension plan.
“The IRS’ actions back that up,” they write. “Over the past several weeks, 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 on its own, but that combined activity tells a story of deep IRS scrutiny. This article discusses that activity, and provides some high-level options for affected advisors and taxpayers.”
To read the full article, click here.