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alliantnational’s Steve Miller and John Dies Discuss Appeals Process and Pre-Audit Tactics in Captive Insurance Examinations

In a March 10 American Bar Association Webinar, Steve Miller and John Dies discussed useful tactics and strategies for dealing with an IRS examination of a captive insurance company. The hour long webinar focused on tax issues for small captive owners both before and after IRS tax controversy arises. Miller discussed pre-audit strategies captive insurance…

Court Denies Conservation Easement Deduction for Defective Contemporary Written Acknowledgement

By Steven Miller, former IRS Acting Commissioner and alliantgroup National Director of Tax On March 23, 2016, the Tax Court issued a decision upholding the IRS’s disallowance of a charitable deduction for a contribution of a conservation easement based on the taxpayer’s failure to satisfy the strict substantiation requirements of section 170(f)(8). In French v.…

District Court Addresses Treaty Benefits Case Involving Claim of IRS Abuse of Discretion

In a case involving unique tax treaty benefit issues, Starr International Co. is challenging the application of a reduced withholding rate under the Switzerland – U.S. income tax treaty. The company is a Swiss-domiciled company that received dividends from a United States company for which withholding tax applied. The U.S District Court for the District…

alliantgroup’s Kathy Petronchak Quoted in Tax Notes

Earlier this month, Kathy Petronchak, alliantgroup’s Director of IRS Practice & Procedure and the former IRS Commissioner of the Small Business/Self-Employed (SB/SE) Division, was quoted in Tax Notes regarding a letter from the IRS Office of Appeals. The letter from Appeals Chief Kirsten Wielobob clarified four specific procedural changes that were recently implemented and provided…
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Washington D.C.
Willard Office Building, Suite 300 1455 Pennsylvania Ave. Washington, D.C. 20004
202.888.7006

© 2024 alliantNational.- All Rights Reserved.

aNlogo-footer3@2x

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

© 2024 alliantNational. - All Rights Reserved.

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