IRS Announces 831(b) Micro-Captive Settlement Initiative
The IRS announced a one-time settlement offer for certain micro-captive insurance participants currently under IRS exam. Per the announcement, the…
199A a deduction or…
With the extended filing season upon us, questions abound on the various nuances of 199A. The Service on January 18,…
The IRS Remains Skeptical of Syndicated Conservation Easements
It is no secret that the IRS has been actively looking at syndicated conservation easements in recent years. While a…
Launching Libra—Regulatory Reaction to Facebook’s Anticipated New Currency
In an age where the concept of “currency” has become a somewhat nebulous concept for consumers and regulators alike, Facebook…
Cryptocurrency – The IRS Efforts to Revamp Immediate Enforcement
In a statement issued on July 26, the IRS has announced that it will send letters to more than 10,000…
The Curious Case of Cryptocurrency
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…
Recent Developments in the Captive Insurance Space
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…
Court of Appeals Denies Injunction Action against Notice 2016-66
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…
