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1403, 2018

Captive Insurance Times: CICA: Standing up to the Irs Can Be Good for the Industry

By |March 14th, 2018|In the news|0 Comments

John Dies, Managing Director of Tax Controversy at Alliantgroup LP, interviewed by Captive Insurance Times in regards to captive insurance and winning a case against the IRS.
March 14, 2018
Published in Captive Insurance Times

1403, 2018

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

By |March 14th, 2018|captives, publishedarticles|0 Comments

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 Conference, Dies suggested the impact of winning a case against the IRS could be felt across the captive industry.

He said: “It is great for the industry when a captive stands up to the IRS, wins and creates a precedent that the industry can use.”

“We have seen the impact in cases where outsiders thought there was not a chance a captive could win and they made changes in the industry–and I believe that is positive for the industry.”

According to Dies, in the right context fighting the case is the correct move for a captive.

He explained: “In many cases, great […]

903, 2018

Tax Notes: How Will TCJA Affect Individuals Electing Corporate Taxation?

By |March 9th, 2018|In the news|0 Comments

Robert Russell, Former Counsel to the Joint Committee on Taxation and U.S. Department of Treasury; alliantgroup Director of International Tax Controversy, Planning and Policy, quoted in Tax Notes.
March 9, 2018
Published in Tax Notes

903, 2018

How Will TCJA Affect Individuals Electing Corporate Taxation?

By |March 9th, 2018|publishedarticles|0 Comments

March 9, 2018
By Andre Velarde
Published in Tax Notes

The Tax Cuts and Jobs Act has brought newfound attention to an election by individuals to treat themselves as corporations, as well as important questions about uncertainties surrounding its interplay with newly enacted international provisions.

Section 962 was drafted in 1962 and until recently was largely unknown to many practitioners. Under that section, U.S. individual shareholders may annually elect to be taxed at the corporate tax rate for their section 951(a) subpart F inclusions. The taxpayer may also claim the deemed- paid foreign tax credit under section 960. The election has its limits, however, as under section 962(d), when an actual distribution is made, the earnings and profits from a controlled foreign corporation that exceed the tax applicable under the section 962 election are also treated as income.

The TCJA committee report, in a terse footnote about section 965, cites to the section 962 […]

2602, 2018

The Hill: Republicans Just Bought the IRS

By |February 26th, 2018|In the news|0 Comments

The Hill Mark Everson, the former IRS commissioner during the George W. Bush presidency, talks about the relationship between the IRS and Republicans after tax reform in his latest piece published in The Hill.
February 26, 2018
Published in The Hill

2602, 2018

Republicans Just Bought the IRS

By |February 26th, 2018|publishedarticles|0 Comments

February 26, 2018
by Mark W. Everson, former IRS Commissioner and alliantgroup Vice Chairman
The Hill

After nine years of a contentious relationship with the Internal Revenue Service, Republicans find themselves in the uncomfortable position of needing the IRS to deliver on tax reform. The stakes are high. In 2016 there were 30 percent more individual income tax returns processed by the IRS than votes cast in the presidential election. And execution matters. Just think of the ObamaCare exchanges, when a botched rollout of the website – involving only a small fraction of the people who interact with the IRS – did lasting damage to a signature legislative achievement supported by a single political party. Here’s what should be done:

Give the IRS the money it needs to pull this off. The service will have to staff up and train personnel in its call centers to accommodate a spike in taxpayer and practitioner […]

1402, 2018

Tax Notes: Transition Tax Guidance Restricts Tax-Year Changes for 2017

By |February 14th, 2018|In the news|0 Comments

Robert Russell, Former Counsel to the Joint Committee on Taxation and U.S. Department of Treasury; alliantgroup Director of International Tax Controversy, Planning and Policy, quoted in Tax Notes.
February 14, 2018
Published in Tax Notes

1402, 2018

Transition Tax Guidance Restricts Tax-Year Changes for 2017

By |February 14th, 2018|publishedarticles|0 Comments

February 14, 2018
By Ryan Finley
Published in Tax Notes

To prevent unintended deferral of transition tax, calendar-year specified foreign corporations (SFCs) will be barred from changing their tax years if the resulting 2017 year would end before December 31, new IRS guidance says.

With its February 13 release of Rev. Proc. 2018-17, the IRS modified prior guidance on changes of tax year to address foreign entities classified as SFCs under the Tax Cuts and Jobs Act (P.L. 115-97). The revenue procedure amends Rev. Proc. 2002-39 and Rev. Proc. 2006-45 to deny any request to change the tax year of an SFC with deferred earnings and profits and a 2017 tax year beginning January 1, 2017, to any date other than December 31, 2017. (Related analysis.)

The new rules will prevent “changes to the annual accounting periods of certain foreign corporations in 2017 under either the existing automatic or general procedures if such change […]

1701, 2018

Tax Notes: TAS Report Could End ‘Hall of Mirrors’ in IRS Appeals Talks

By |January 17th, 2018|In the news|0 Comments

Kathy Petronchak, former IRS Small Business/Self-Employed Division commissioner and alliantgroup Director of IRS Practices and Procedure, interviewed by Tax Notes.
January 17, 2018
Published in Tax Notes

1701, 2018

TAS Report Could End ‘Hall of Mirrors’ in IRS Appeals Talks

By |January 17th, 2018|publishedarticles|0 Comments

January 17, 2018
By Stephanie Cumings
Published in Tax Notes

IRS Appeals could reverse course on letting counsel and compliance employees participate in its work, after the latest Taxpayer Advocate Service report said the collaboration threatens Appeals’ independence.

If the IRS continues allowing this type of participation, it will further erode taxpayer faith in the appeals process, practitioners told Tax Analysts.

Sheri A. Dillon of Morgan, Lewis & Bockius LLP hopes the TAS report leads to compliance and counsel only being invited to an appeal when “it’s mutually agreed upon with the taxpayer.” Not only will this ensure that taxpayers “do not get caught in an IRS hall of mirrors” during the negotiations, it will also protect Appeals’ independence, efficiency, and integrity, Dillon said January 12. She also wants Appeals to reestablish face-to-face conferences.

Kathy Petronchak of Alliantgroup LP said compliance personnel’s participation in appeals needs to change. “There are substantial opportunities for compliance to […]

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