Tag: 2016-66

Recent Microcaptive Case Undermines Promoted Structure

Asset Protection, Business Transactions, Cases, Income Tax, Tax, Tax Controversy, Tax Court

A recent Tax Court decision underscores an increasingly rigorous examination of Section 831(b) microcaptive insurance arrangements.[1] This ruling may be insightful to taxpayers considering or currently operating microcaptives, has broad implications for businesses seeking legitimate tax incentives created by Congress. Overview of the Case The case at hand involves the Internal Revenue Service’s (“IRS”) rejection…
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Evaluating the Landscape: Impact of CIC Services, LLC Case on Attorneys’ Fees and Government Fairness

Cases, Compliance, Current Events, District Court, Income Tax, Tax, Tax Controversy, Tax Related Cases

The recent opinion from the United States District Court, Eastern District of Tennessee, continues the saga of the case of CIC Services, LLC (“CIC”) and has implications for taxpayers seeking to recover attorneys’ fees under the Equal Access to Justice Act (“EAJA”) and for its broader reflections on governmental fairness, particularly those looking to challenge…
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