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Cryptocurrency Creating Taxpayer Conundrums

As the tax season winds to a close, tax practitioners and taxpayers can once again begin the process of looking ahead. However, this tax filing season has left several questions unanswered. In particular, the treatment of certain cryptocurrency transactions have left taxpayers searching for answers without a clear path forward. Generally, the basic tax treatment…

Avrahami: Reviewing the Situation

August 23, 2017 by Steven Miller, former IRS Acting Commissioner and alliantgroup National Director of Tax, and John Dies, alliantgroup Managing Director of Tax Controversy Captive Insurance Times On 21 August, the US Tax Court issued its long awaited decision on Avrahami v Commissioner. After waiting nearly two and a half years from when the…

Alliantgroup’s Steven Miller and Robert Russell present at the Federal Bar Association’s Federal Tax Conference in Washington D.C.

Steven Miller, alliantgroup’s National Director of Tax, presented on a panel with a current IRS executive to discuss current IRS enforcement initiatives. Key areas of focus were on the newly announced IRS audit campaigns, examination procedures, and the rebirth of reportable transactions and transactions of interest reporting. Russell was joined by members of the Treasury…

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…

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…

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Washington D.C.
Willard Office Building, Suite 300 1455 Pennsylvania Ave. Washington, D.C. 20004
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© 2021 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

© 2021 alliantNational. - All Rights Reserved.

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