IRS Issues Guidance on Section 199: Rental Real Estate Safe Harbor
On September 24, 2019, the IRS issued Revenue Procedure 2019-38, which implements a safe harbor under which a real estate…
alliantNational Helps Client Overcome Wrongly Denied Business Deductions
The U.S. Tax Court recently ruled in WP Realty, LP, Olympia Realty, Inc., Tax Matters Partner v. Commissioner of Internal…
GILTI Partnership Pivot – The latest news from Treasury
The Tax Cuts and Jobs Act, passed at the end of 2017, made significant changes to the structure of the…
IRS Announces 831(b) Micro-Captive Settlement Initiative
The IRS announced a one-time settlement offer for certain micro-captive insurance participants currently under IRS exam. Per the announcement, the…
Cryptocurrency – The IRS Efforts to Revamp Immediate Enforcement
In a statement issued on July 26, the IRS has announced that it will send letters to more than 10,000…
COURT RULING MAY ARM IRS FOR MICRO-CAPTIVE INSURER CRACKDOWN
March 13, 2017 By Allyson Versprille Bloomberg BNA An Arizona jeweler set up a “micro-captive” arrangement to insure itself against terrorist attacks. The IRS calls it a tax-avoidance maneuver. If a U.S. Tax Court judge agrees, and delivers a far-reaching opinion, he could strengthen the agency’s hand against such small captive insurers. “For the IRS…
Court of Appeals Denies Injunction Action against Notice 2016-66
On May 22, 2019, the Sixth Circuit Court of Appeals upheld the District Court’s holding that Notice 2016-66 does not violate the Administrative Procedure Act (APA). The District Court held that it didn’t have subject matter jurisdiction over the case because the Anti-Injunction Act and Declaratory Judgment Act bar law suits seeking to restrain the…
Committee On Ways and Means: SECTION-BY-SECTION SUMMARY OF H.R. 5771, THE “TAX INCREASE PREVENTION ACT OF 2014″
H.R. 5771 would extend, for one year (generally through the end of 2014), a number of tax relief provisions that expired either at the end of calendar year 2013 or during 2014, thus preventing tax increases on millions of families and businesses as the tax year 2014 filing season begins early next year. By enacting…
