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HOUSTON, March 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 […]
HOUSTON, Sept. 8, 2017 /PRNewswire/ — alliantgroup is proud to announce that John Dies, alliantgroup’s Managing Director of Tax Controversy, has been appointed to the American Bar Association’s Captive Insurance Committee.
“I am honored to have been selected to the ABA’s Captive Insurance Committee,” said Dies. “The captive insurance space, specifically in the area of micro-captives, is undergoing major compliance changes and people will need to have the most up to date information in order to plan accordingly. By joining the committee, it is my hope to increase the awareness of the benefits of micro-captives and help taxpayers understand the steps they should be taking to ensure everything is done by the book and in line with IRS guidelines.”
A seasoned trial attorney, Dies brings to the committee years of first-hand experience in representing and working with taxpayers on micro-captive insurance compliance. He is a prominent […]
HOUSTON, Aug. 24, 2017 /PRNewswire/ — In the wake of the U.S. Tax Court’s long-awaited ruling in the case of Avrahami v. Commissioner, alliantgroup will be hosting a free webinar for CPAs next week to discuss the implications of the ruling on the captive insurance industry. This webinar will qualify attendees for 1 hour of CPE (Continuing Professional Education) credit.
The presentation, “The World After Avrahami,” will take place on Tuesday, August 29th at 12:00 pm CT and will be hosted by Steven Miller, former IRS Acting Commissioner and alliantgroup National Director of Tax, and John Dies, alliantgroup Managing Director of Tax Controversy.
Avrahami is the first major case in the area of micro-captive insurance and will have substantial implications for the industry. During this presentation, Miller and Dies will cover the Tax Court’s decision, how […]
HOUSTON, Aug. 23, 2017 /PRNewswire/ — The U.S. Tax Court has issued its long awaited decision in Avrahami v. Commissioner, and while many had hoped for a wide-ranging opinion providing a clear path forward on micro captives, alliantNational (alliantgroup’s Washington, D.C. based office) sees the ruling as falling short in this regard. The facts in Avrahami led the court to issue a very fact intensive ruling, meaning taxpayers should be cautious when trying to extract general rules or holdings from the case.
As part of its broader ruling on the Avrahami’s micro-captive, the court held that the risk distribution requirements for insuring either related or unrelated entities were not met and that the arrangement was found to not constitute insurance. However, when it comes to the decision over risk distribution, there are two key takeaways for taxpayers. First, the court did not offer its opinion on the number of […]
HOUSTON, June 23, 2017 /PRNewswire/ — alliantgroup, a leading tax consultancy and the nation’s premier provider of specialty tax services, and alliantNational, the firm’s Washington, D.C. based national office, are proud to announce the launch of a new Section 1603 renewable energy grants service line.
Originally passed as part of the American Recovery and Reinvestment Act of 2009, Section 1603 is a green energy subsidy program created by Congress to reimburse grant recipients for a portion of the cost to install certain types of energy systems at business locations. The Section 1603 grant is available in lieu of other energy tax incentives such as the Energy Investment Tax Credit (ITC) and the Renewable Electricity Production Tax Credit (PTC), but has the benefit of being a cash grant, unlike the non-refundable ITC and PTC […]
HOUSTON, June 19, 2017 /PRNewswire/ — alliantgroup National Director of Tax Steven Miller and Managing Director of Tax Controversy John Dies will be hosting a webinar with Bloomberg BNA entitled “Captive Insurance—The New IRS Approach” this Thursday at 10:30 am CDT to discuss Internal Revenue Service scrutiny of small captive insurance arrangements.
Many small and mid-size businesses use captive insurance companies as a way to manage insurance costs. Unfortunately, these arrangements are frequently abused to generate a business deduction, which has led captive insurance to make the IRS’s dirty dozen list three years in a row.
As a former Acting Commissioner of the IRS and Deputy Commissioner for Services and Enforcement, Steven Miller has more than 25 years experience working at every level of the IRS. John Dies has represented hundreds of […]
HOUSTON, Sept. 21, 2015 /PRNewswire/ — alliantgroup is proud to announce the reappointment of Kathy Petronchak, the firm’s Director of IRS Practice & Procedure, to the American Institute of CPAs Tax Executive Committee for 2016. Currently a member of the firm’s alliantNational office in Washington D.C., Petronchak has a combined 35 years of experience in directing IRS compliance activities and providing tax controversy services. In her current role with alliantNational, the former IRS Commissioner of the Small Business/Self-Employed Division has been helping both taxpayers and practitioners gain a greater understanding of IRS procedures, compliance standards and the best solutions available for taxpayers involved in disputes with the IRS.
Serving as a member of the AICPA Tax Executive Committee, Petronchak will be leveraging her experience to provide perspective on important issues facing AICPA members each day. As an authoritative body, the AICPA’s Tax Executive Committee approves all policy recommendations for the organization’s […]
HOUSTON, Aug. 31, 2015 /PRNewswire/ — alliantgroup is proud to announce the additions of former IRS leaders Howard Lewis, Dorothy Taylor and Ron Cerruti as advisors to the firm’s alliantNational office in Washington, D.C. All three are former managers with over 30 years of experience at the Service and will add to alliantNational’s growing bench of former IRS personnel, offering their counsel on issues related to standard IRS practice and procedure, tax controversy and other complex tax issues.
“I could not be happier to welcome Howard, Dorothy and Ron as advisors to our firm,” said Steven Miller, former IRS Acting Commissioner and alliantgroup National Director of Tax. “Having worked with all three during my years at the IRS, I have nothing but admiration for their public service and I look forward to their contributions in shaping the future of alliantNational. Their hands-on experience in the world of tax controversy will be […]
HOUSTON, TX. MAY 12, 2015 – alliantgroup is proud to announce the launch of alliantNational in Washington, D.C. The formation of alliantNational represents a bold step for the firm, expanding the overall scope and direction of the company’s specialty tax services. In addition to the firm’s current work in identifying valuable federal and state tax incentives, alliantNational offers a number of other services to CPAs and U.S. businesses to assist in navigating difficult tax matters, planning for the future and, in particular, working with the IRS and state tax officials.
Led by former IRS Acting Commissioner and alliantgroup National Director of Tax, Steven Miller, and former Senior Counsel to the U.S. Senate Finance Committee and alliantgroup National Managing Director, Dean Zerbe, alliantNational is comprised of a world-class team of seasoned former IRS executives, key congressional staff, technical experts and experienced litigators. Experts in law and the legislative process, alliantNational has experience […]
HOUSTON, TX. MARCH 4, 2015 – On Monday, March 2, former IRS Acting Commissioner and alliantgroup National Director of Tax, Steven Miller, and former Senior Counsel to the U.S. Senate Finance Committee and alliantgroup National Managing Director, Dean Zerbe, participated in a roundtable discussion hosted by the American Bar Association (ABA). Joined by seven other experts in the realm of captive insurance, the panel reviewed a number of recent actions taken by the IRS as well as the Senate Finance Committee in regards to micro captive insurance companies.
While the tax code allows for captive insurance companies – providing businesses an alternative to managing risk – it is important that companies are engaged in purchasing actual insurance that is appropriately priced. The IRS is actively examining several companies that market captive insurance to small and medium businesses as well as those business owners that form captive insurance companies.
“The IRS is looking […]