Daniel J. Bell
Subscribe to Daniel J. Bell's PostsDaniel (Danny) J. Bell focuses his practice on domestic and international estate, gift and income tax planning. He has assisted clients with cutting-edge estate, income and gift tax mitigation strategies, including domestic and offshore tax compliance, tax controversy and litigation, pre-immigration, expatriation and business succession planning, estate and trust administration, as well as family multigenerational wealth preservation. Danny has also advised high-net-worth individuals with sophisticated tax and wealth transfer planning and implementation. Read Danny Bell's full bio.
IRS Criminal Investigation Division Is on the Hunt for Malta Pension Plan Participants and Promoters
By Daniel J. Bell, Steven Hadjilogiou, Kevin Spencer and Evan Walters on Jul 25, 2023
Posted In Uncategorized
There has been a growing trend of US taxpayers contributing non-cash assets, such as appreciated property, securities and cryptocurrency, into Maltese pension plans since the US-Malta Tax Treaty went into effect in 2011. These transactions were marketed to many US taxpayers as a way to cash in on their earnings without being subject to US federal taxation....
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Tax Court Tells IRS It Cannot Assess or Collect Certain Tax Penalties
By Daniel J. Bell, Steven Hadjilogiou, Sarah M. Raben and Kevin Spencer on Apr 26, 2023
Posted In Court Procedure Matters, IRS Guidance, Tax Refunds, Trial Courts
On April 3, 2023, the US Tax Court issued its opinion in Farhy v. Commissioner, holding that the Internal Revenue Service (IRS) lacked the statutory authority to both assess tax penalties under Internal Revenue Code (Code) Section 6038(b) and collect said penalties via a levy against the taxpayer. The decision in Farhy is significant because the IRS regularly...
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Tax Court Rules That the IRS Cannot Assess or Collect Certain Tax Penalties
By Kevin Spencer, Daniel J. Bell and Steven Hadjilogiou on Apr 5, 2023
Posted In Court Procedure Matters, IRS Guidance, Tax Refunds, Trial Courts
On April 3, 2023, the US Tax Court issued its opinion in Farhy v. Commissioner, ruling that the Internal Revenue Service (IRS) could neither assess tax penalties under Internal Revenue Code (Code) Section 6038(b) against Alon Farhy nor collect those penalties via a levy. This is a significant development because the IRS automatically assesses these penalties on any late-filed Form...
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IRS OVDP Ending | Time Is Now for Coming into US Tax Compliance – Especially for Those with Willfulness Issues
By Daniel J. Bell, K. Christy Vouri-Misso and McDermott Will & Emery on Mar 16, 2018
Posted In Alternative Dispute Resolution, IRS Audits, IRS Guidance, Settlements, Uncategorized
On March 13, 2018, the Internal Revenue Service (IRS) announced that it will begin ramping down the current Offshore Voluntary Disclosure Program (OVDP) and urged taxpayers with undisclosed foreign assets to apply for the program prior to its close on September 28, 2018. We have previously reported on developments in the OVDP. Access the full article.
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Release of “Panama Papers” May Encourage New Wave of OVDP Submissions
By Daniel J. Bell, Jonathan D. Lockhart, Leigh-Alexandra Basha and McDermott Will & Emery on Apr 8, 2016
Posted In IRS Audits, IRS Guidance, Uncategorized
On April 3, 2016, the International Consortium of Investigative Journalists (ICIJ) indicated that it acquired sensitive documents that belonged to the Panamanian law firm, Mossack Fonseca & Co., about the offshore holdings of some of the world’s most prominent and wealthy individuals. The leak has received substantial mainstream media coverage due to the identity of...
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