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So far alliantNational has created 403 blog entries.
1607, 2019

The Curious Case of Cryptocurrency

By |July 16th, 2019|alliantNational Blog, Resource Library|0 Comments

Cryptocurrency is…complicated. You’ve definitely heard about it, and probably know someone who has either lost big or became an overnight millionaire because of it. Buzz words and terms get thrown around constantly like “blockchain” and “mining”, but what exactly is cryptocurrency? And why is IRS’ treatment of the new currency shrouded in so much mystery?

As a decentralized, virtual form of currency that only exists in the digital world, cryptocurrency is truly unique. There is no dealing with tangible crypto-dollars or crypto-cents, as well as no regulation or oversight by any national government or central bank.

Cryptocurrency exists in an exclusively virtual state and relies on a technology known as blockchain to keep it secure and transferrable. Cryptocurrencies are created through a “mining” process, whereby miners use powerful computers to authenticate transactions in a digital ledger of transactions. People can trade cryptocurrency […]

307, 2019

Recent Developments in the Captive Insurance Space

By |July 3rd, 2019|alliantNational Blog, Resource Library|0 Comments

We at alliantNational wanted to discuss some recent developments with regard to the captive insurance space – specifically, with respect to IRC § 831(b) micro-captives. However, let’s begin by walking through the definition of captive insurance.

When businesses can’t find affordable commercial insurance to cover their risks, they may establish an insurance company of their own to do it for them. This company is what we refer to as a captive insurance company. The Internal Revenue Code provides that captives earning less than $2.2 million in premiums may make an election to only have their investment income taxed. These are what are referred to as 831(b) captives or “micro-captives”.

Due to their increasing popularity and favorable tax treatment, our friends at the IRS have increased their scrutiny of micro-captives. Following the rulings in Avrahami v. C.I.R., Reserve Mechanical v. C.I.R., and most recently Syzygy Insurance v. C.I.R. (all U.S. Tax Court cases), taxpayers […]

3005, 2019

Court of Appeals Denies Injunction Action against Notice 2016-66

By |May 30th, 2019|alliantNational Blog, Resource Library|0 Comments

On May 22, 2019, the Sixth Circuit Court of Appeals upheld the District Court’s holding that Notice 2016-66 does not violate the Administrative Procedure Act (APA). The District Court held that it didn’t have subject matter jurisdiction over the case because the Anti-Injunction Act and Declaratory Judgment Act bar law suits seeking to restrain the Government’s ability to assess and collect tax. The Sixth Circuit Court of Appeals agreed – holding that while the IRS “ not have a great history of complying with APA procedures, having claimed for several decades that their rules and regulations are exempt from those requirements,” the Court still does not have subject matter jurisdiction over suits seeking to enjoin the assessment or collection of taxes.

The original suit, filed by CIC Services, Inc., sought to enjoin the IRS from enforcing the disclosure requirements under Notice 216-66. After the District Court held that it didn’t have subject matter jurisdiction in […]

1804, 2019

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

By |April 18th, 2019|alliantNational Blog, Resource Library|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 […]

2702, 2019

alliantNational Amicus Brief Helps Pave Way to Victory for Taxpayers at Ninth Circuit

By |February 27th, 2019|Resource Library|0 Comments

alliantNational is proud to announce that the U.S. Court of Appeals for the Ninth Circuit has ruled in favor of a taxpayer couple supported by the firm, saying the IRS failed to give the couple a meaningful opportunity to volunteer certain tax records on their own.

The Court determined that the Internal Revenue Service 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 the IRS had […]

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 […]

1402, 2019

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

By |February 14th, 2019|Resource Library|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

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