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Court Reduces ARRA 1603 Payment

Congress created the Section 1603 grant program as part of the American Recovery and Reinvestment Act (ARRA) of 2009. The purpose of this grant is to encourage installation of specified energy property used in a trade or business. The grant reimburses a portion of the costs associated with these energy facilities. The Court of Federal…

alliantNational January 2016 EO Webinar and Special Edition Newsletter

On January 26, 2016, alliantgroup conducted a webinar entitled “Exempt Organizations:  2015 Recap and the Year Ahead.” The presenters included Steven Miller, alliantgroup National Director of Tax; Dean Zerbe, alliantgroup National Managing Director; and Ron Schultz, alliantgroup Senior Technical Advisor. Each of the presenters discussed some of the most significant issues affecting nonprofits and exempt…

Department of Justice Open to Communication with Foreign Financial Institutions

The United States Department of Justice Tax Division (DOJ) has announced they are open to talk with any foreign financial institution that would like to resolve potential U.S. tax exposure. Acting Assistant Attorney General, Caroline Ciraolo, stated that institutions outside of the formal Swiss Bank Program should consider meeting with the DOJ to attempt to…

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…
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© 2022 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

© 2022 alliantNational. - All Rights Reserved.

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