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1804, 2019

Tax Court Issues section 831(b) Ruling in Syzygy Insurance

By |April 18th, 2019|alliantNational Blog|0 Comments

On April 10th, The Tax Court issued its latest opinion involving micro-captives. In mostly finding for the IRS, the Court maintains the analytical framework set forth in its opinions in Avrahami (2017) and Reserve Mechanical (2018). It also provides a window into what happens when the IRS invalidates the 831(b) election.

The Court found that Syzygy, a Delaware captive insurance company, failed to establish that it was an insurance company for tax purposes on the grounds that it failed to properly distribute risk and that the arrangement was not “insurance in the commonly accepted sense.”

In its analysis of Syzygy’s risk distribution, the Court relied on Avrahami and Reserve, focusing on aspects of the risk pool.  The insured entities in this case have 400 employees and operate in six different locations. Interestingly, the Court, however, did not analyze whether there were a sufficient number of independent risk exposure units to establish risk […]

503, 2019

alliantNational Amicus Brief Helps Secure Victory for Taxpayers at Ninth Circuit

By |March 5th, 2019|Press Releases|0 Comments

HOUSTONMarch 5, 2019 /PRNewswire/ — alliantNational welcomes the U.S. Court of Appeals for the Ninth Circuit’s ruling in J.B.; P.B. v. United States, finding the Internal Revenue Service (IRS) failed to give a taxpayer couple a meaningful opportunity to volunteer tax records in response to an agency request.

The Court determined that the IRS hadn’t provided sufficient notice to Joseph and Patricia Baxter when it issued a summons to the California Supreme Court seeking various documents as a part of the agency’s National Research Program.

The leadership of alliantNational, as parties of the associated law firm Zerbe Miller Fingeret Frank & Jadav LLP, submitted an amicus brief on behalf of the couple, arguing that the tax code and legislative history required the IRS to give the couple an adequate chance to respond to its document request before contacting a third-party.

The Ninth Circuit ruled on February 26 that […]

1402, 2019

Writing the Playbook: alliantNational’s Miller and Amin Contribute to ABA’s Captive Insurance Handbook

By |February 14th, 2019|In the news, Uncategorized|0 Comments

alliantNational’s own Steven Miller and Meeren Amin co-authored a chapter in the American Bar Association’s 2018 Captive Insurance Deskbook for the Business Lawyer.
February 14, 2019
Published in 2018 Captive Insurance Deskbook for the Business Lawyer

1402, 2019

Writing the Playbook: alliantNational’s Miller and Amin Contribute to ABA’s Captive Insurance Handbook

By |February 14th, 2019|publishedarticles|0 Comments

alliantNational’s own Steven T. Miller and Meeren Amin co-authored a chapter in the American Bar Association’s 2018 Captive Insurance Deskbook for the Business Lawyer. The book helps attorneys navigate the often-murky paths of captive insurance companies and offers suggestions on whether a captive is a suitable option for a business owner.

Miller and Amin co-authored a chapter on “Captive Insurance Tax Controversy,” where the two discussed how the Internal Revenue Service conducts audits of captives, the appeals process if the agency determines a captive has violated pertinent law, how to prepare for possible litigation and effective pre-audit strategies for managing a captive.

The book’s publication comes at a time when most Fortune 500 companies, as well as many small to mid-sized businesses and tax-exempt organizations are involved with captives. It features a wide-range of tax controversy professionals and serves as a comprehensive outline for any business that is looking into the […]

410, 2018

Tax Notes: New Business Meals Guidance Creates Substantiation Concerns

By |October 4th, 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.
October 4, 2018
Published in Tax Notes

410, 2018

New Business Meals Guidance Creates Substantiation Concerns

By |October 4th, 2018|publishedarticles|0 Comments

October 4, 2018
By Stephanie Cumings
Published in Tax Notes

Taxpayers might not be prepared to separately document meals this year as required by new guidance on the business meals deduction, according to practitioners.

Whether client business meals would still be deductible was “the big issue” coming out of the 2017 tax law’s changes to meals and entertainment, Michael L. Hadley of Davis & Harman LLP told Tax Notes.

An October 3 IRS notice makes clear that those meals will continue to be 50 percent deductible, but it requires, among other things, that meals provided during an entertainment activity be separately billed.

Employers will need to look at how they’ve tracked their spending, and they may have to reconstruct some invoices this year to meet the new substantiation requirement, Hadley said. Ruth M. Wimer of Winston & Strawn LLP agreed that properly documenting meal expenses could be an issue.

Under the prior law, both meals and […]

310, 2018

Bloomberg Government: You Can Still Deduct a Client’s Meal on a Night Out, IRS Says

By |October 3rd, 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 Bloomberg Government.
October 3, 2018
Published in Bloomberg Government

310, 2018

You Can Still Deduct a Client’s Meal on a Night Out, IRS Says

By |October 3rd, 2018|publishedarticles|0 Comments

October 3, 2018
By Laura Davison and Lynnley Browning
Published in Bloomberg Government

The Internal Revenue Service is giving businesses a tax break they thought they had lost in the tax overhaul last year — write-offs for wining and dining clients.

The agency said Wednesday companies can still deduct 50 percent of meals while entertaining clients and customers, clearing up confusion about whether tax law changes last year had completely eliminated that benefit.

The bill that President Donald Trump signed eliminated the deduction for so-called entertainment expenses — golf outings, cruises and concert tickets. Tax professionals also thought that ban included food purchased while taking clients out. The IRS said the costs of business meals while entertaining clients are still deductible as long as they’re reflected on a separate receipt.

“Food and beverages that are provided during entertainment events will not be considered entertainment if purchased separately from the event,” the IRS said in a statement.

For […]

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

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