Steven Miller Co-Hosts ABA Webinar on Captive Insurance

Steven Miller, alliantgroup’s National Director of Tax and the former IRS Acting Commissioner, recently co-hosted an ABA Webinar on captive insurance, focusing on the government’s brief in the Tax Court case of Avrahami v. Commissioner.

The case represents the IRS’ first challenge of an IRC § 831(b) captive insurance company in court. Drawing upon his 25 years of experience at the Service, Miller elaborated on the IRS’ position and analyzed the strengths and weaknesses of their argument.

Steven Miller Quoted in Tax Notes Praising New LB&I Deputy Commissioner

Steven Miller was also recently quoted in Tax Notes praising the appointment of Rosemary Sereti as the new Deputy Commissioner of the IRS Large Business and International (LB&I) Division.

Steven Miller, former acting IRS commissioner and currently with alliantgroup, praised the decision to promote Sereti. “I think she’s splendid,” he said, adding that he’s known her since he was the commissioner of what was formerly the Large and Midsize Business Division.

As noted in the Tax Notes piece, Sereti’s appointment comes at a time when LB&I is facing major organizational changes. LB&I Commissioner Douglas O’Donnell announced last September that sweeping changes would be made next year to streamline both compliance and enforcement. In the Tax Notes release, Miller comments on the challenges ahead for the current commissioner and newly appointed deputy commissioner.

Miller said the reorganization will be a difficult job for both Sereti and O’Donnell. “I think she was the right choice,” he said, adding that Sereti and O’Donnell will be a wonderful mix because Sereti “brings a lot of knowledge on the domestic side, whereas [O’Donnell] brings a tremendous amount from the foreign international practice of LB&I.”

alliantgroup Welcomes Three Former IRS Leaders as Advisors to alliantNational Office

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. All three are former managers with over 30 years of experience at the Service, adding to alliantNational’s growing bench of former IRS personnel.

“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.”

Working in an advisement role for the firm, all three former IRS leaders will be leveraging their knowledge and experience for the benefit of tax practitioners and U.S. businesses. In particular, all three will be offering their counsel on issues related to standard IRS practice and procedure, tax controversy and other complex tax issues.

“Their hands-on experience in the world of tax controversy will be a great asset to our clients and offer an insider’s perspective into what the IRS and state tax authorities are looking for in regards to compliance and risk management,” said Miller.