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608, 2018

The Wayfair Ruling and What it Means for Small Business

By |August 6th, 2018|publishedarticles|0 Comments

I know it’s August and probably the last thing on your mind is the Supreme Court’s recent Wayfair decision on out-of-state sellers.

However, given the long-term implications of the case and its anticipated impact on your clients and e-commerce in general, I thought you’d be interested in this recent Accounting Today piece. In the article, I discuss the ruling’s potential effect on small and medium businesses:

  • Although there was nothing about protecting small business in the actual holding of the Wayfair decision, it did have a lot of vague ideas on the subject, observed Dean Zerbe, alliantgroup’s national managing director and former senior counsel with the Senate Finance Committee. “Good luck with that! I don’t think states will show a restraining hand,” he said.
  • “Right after they have sales tax nexus, they’ll try to extend it to business activity tax,” Zerbe predicted. “You’re here for sales tax — […]
208, 2018

Tax Notes: U.S. Transition Tax Regs Provide Clarity, Limited Relief

By |August 2nd, 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.
August 2, 2018
Published in Tax Notes

208, 2018

U.S. Transition Tax Regs Provide Clarity, Limited Relief

By |August 2nd, 2018|publishedarticles|0 Comments

August 2, 2018
By Andre Velarde
Published in Tax Notes

Lengthy transition tax regs may offer practitioners some reassurance in fleshing out more details, but they don’t venture much outside the original scope of previous guidance.

“With the release of the regs, not absolute certainty as to the transition tax liability, but pretty close,” Jose Murillo of EY said.

The highly anticipated proposed regs (REG-104226-18), released August 1, are one of the first pieces of key guidance from the Tax Cuts and Jobs Act (P.L. 115-97) to be released.

Practitioners had been anxiously awaiting more guidance on the transition tax because three previous notices, while detailed, left many questions unanswered. The 249-page reg package is divided into nine sections, including rules on adjustments to earnings and profits and basis, determining section 965(c) deductions, disregarding some transactions, foreign tax credits, elections and payments, and affiliated groups.

“Despite their length, the proposed regulations do not break […]

2706, 2018

Tax Notes: Unclear if the IRS Can Save the Client Business Meal

By |June 27th, 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.
June 27, 2018
Published in Tax Notes

2706, 2018

Unclear if the IRS Can Save the Client Business Meal

By |June 27th, 2018|publishedarticles|0 Comments

June 27, 2018
By Stephanie Cumings
Published in Tax Notes

Tax observers are torn on whether the IRS has the power to restore the deduction for client business meals that Congress seems to have unintentionally axed in the 2017 tax law.

While some practitioners contend that the IRS can salvage the deduction, one professor argues that Congress will have to amend the law if it really intended to keep client business meals deductible. The answer hinges on whether client business meals constitute “entertainment.” Under the prior law, entertainment expenses were 50 percent deductible if they met certain qualifications, but the Tax Cuts and Jobs Act (P.L. 115-97) eliminated the deduction altogether.

“Up until this change in the law, it didn’t really matter whether or not food and beverage was considered entertainment because it was 50 percent deductible either way,” Michael L. Hadley of Davis & Harman LLP told Tax Analysts.

The TCJA conference report […]

3105, 2018

Tax Notes: Global Settlement Offer for Captive Transactions Could Be Tricky

By |May 31st, 2018|In the news|0 Comments

Steven T. Miller, National Director of Tax at Alliantgroup LP, and Mark Everson interviewed by Tax Notes in regards to captive transactions.

May 31, 2018
Published in TaxNotes

3105, 2018

Global Settlement Offer for Captive Transactions Could Be Tricky

By |May 31st, 2018|publishedarticles|0 Comments

May 31, 2018
By Emily L. Foster
Tax Notes

The IRS could resolve captive insurance transaction disputes with a global settlement, as it did for abusive transactions in the 2000s, but tax professionals say the trick is to root out the bad actors.

Microcaptive insurance cases are seeing high volume in three areas — examination, appeals, and litigation — and could be ripe for a global settlement initiative, according to several tax professionals. Their estimates range from hundreds of outstanding cases involving captive insurers — companies wholly owned and controlled by their insureds — to potentially thousands of them. The IRS had no immediate comment on how many cases it is dealing with.

But the tax professionals warned that the solution won’t be as simple as offering settlement programs to captive insurance abusers, because the agency’s first and largest hurdle is determining which operations are legitimate and which are misusing the tax code.

Global settlement […]

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

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