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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The 2024 Dirty Dozen – The IRS’s Annual Warning

Compliance, Current Events, Employment Tax, Income Tax, Regulatory, Tax, Tax Controversy

Every year, the Internal Revenue Service (“IRS”) releases its “Dirty Dozen.” The Dirty Dozen, as written previously about by my colleague, Devin Mills,[1] is a list of twelve prevalent scams the IRS bodes taxpayers to be weary of during tax season, as they “put taxpayers, businesses, and the tax professional community at risk of losing…
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