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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…

Tax Pros Seeking Clue On Small Captive Insurance Cos.

October 13, 2017 By Eric Kroh Law 360 As the Internal Revenue Service continues to scrutinize the tax treatment of small captive insurance companies, tax practitioners are looking to a trio of cases before the U.S. Tax Court to discern where the lines will be drawn between legitimate insurers and shams. The cases — one that…

Irs Wins Tax Court Ruling in Captive Insurance Case

Published in Accounting Today By Michael Cohn The Internal Revenue Service has prevailed in U.S. Tax Court in a case involving an Arizona jewelry store business that received a tax break by insuring itself for millions of dollars, in part against the risk of terrorism. Benyamin and Orna Avrahami, a couple who own three jewelry…

Avrahami Decision Offers Microcaptives Details, No Bright Line

August 23, 2017 By Emily L. Foster Published in TaxNotes Although the Tax Court’s long-awaited Avrahami decision provided a detailed analysis shedding some light on what might constitute insurance for a microcaptive arrangement, it didn’t provide clear guidance on resolving long-standing issues, according to some practitioners. IRS officials and practitioners “were hoping for a bright…

CICA: Standing up to the IRS can be good for the industry

March 14, 2018 By Ned Holmes Published in captive insurance times For a good captive, standing up to the Internal Revenue Service (IRS) may be the right answer and could positive for the industry as a whole, says John Dies, managing director of tax controversy at alliantgroup. Speaking at Captive Insurance Companies Association’s (CICA) 2018…
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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

© 2022 alliantNational. - All Rights Reserved.

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