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Ways and Means Tax Proposal

By Dean Zerbe, alliantgroup National Managing Director As I’ve mentioned earlier, I don’t expect much to happen in tax this election year—except for some small-ball items closer to the end of the year (for example, provisions to further address identity theft). Nothing has changed on that front. So with the presidential election in full swing…

Temporary Regs – ASC on Amended Returns

4830-01-p] DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1 [TD 9666] RIN 1545-BL79 Alternative Simplified Credit Election AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Final and temporary regulations. SUMMARY: This document contains final and temporary regulations relating to the election of the alternative simplified credit. The final and temporary regulations will affect…

IRS Faces Difficulties in 2015

John Koskinen stepped into his role as Commissioner of the IRS amid significant troubles for the agency, and many observers believe that the commissioner has handled his new role well. Specifically, many note that at a time of difficulty for the IRS, the commissioner boosted employee morale, having fought for employee bonuses, toured IRS facilities…

Tax Court Issues section 831(b) Ruling in Syzygy Insurance

On April 10th, The Tax Court issued its latest opinion involving micro-captives. In mostly finding for the IRS, the Court maintains the analytical framework set forth in its opinions in Avrahami (2017) and Reserve Mechanical (2018). It also provides a window into what happens when the IRS invalidates the 831(b) election. The Court found that…

The Curious Case of Cryptocurrency

Cryptocurrency is complicated. You’ve definitely heard about it, and probably know someone who has either lost big or became an overnight millionaire because of it. Buzz words and terms get thrown around constantly like “blockchain” and “mining”, but what exactly is cryptocurrency? And why is IRS’ treatment of the new currency shrouded in so much…

Recent Developments in the Captive Insurance Space

We at alliantNational wanted to discuss some recent developments with regard to the captive insurance space – specifically, with respect to IRC § 831(b) micro-captives. However, let’s begin by walking through the definition of captive insurance. When businesses can’t find affordable commercial insurance to cover their risks, they may establish an insurance company of their…
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aNlogo-footer3@2x

Washington D.C.
Willard Office Building, Suite 300 1455 Pennsylvania Ave.
Washington, D.C. 20004
202.888.7006

© 2023 alliantNational. - All Rights Reserved.

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