Resources Archive
August 22, 2017
Metroplex Practice Management Group... [ read ]
August 22, 2017
In the First Case Ever Decided Involving IRC Section 831(b) Microcaptive Insurance Planning, the Tax Court Delivers the IRS a Critical First Win...
[ read ]
On August 21, 2017, the Tax Court handed the IRS a critical victory in the first ever case deciding an IRS challenge to an IRC section 831(b) microcaptive insurance arrangement. This decision follows an over three year enforcement push by the IRS against the small captive insurance industry, an initiative that ensnarled captive managers and taxpayers alike as well as landed microcaptives on the IRS' dirty dozen lists. But a ruling issued just days before that decision reveals that the IRS is not seeking to disavow all captive insurance arrangements – perhaps just cull out some of the bad apples.
August 22, 2017
When "Mostly" is Not Enough Part One: IRS Issues New Warning to Taxpayers of When Compliance is not "Substantial"...
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In recent months, the IRS has fired two separate shots across the proverbial bow, highlighting the dangers of "incomplete" or "inadequate" reporting as it relates to imposition of penalties and the elongation of the statute of limitations. This blog post explores an International Practice Unit issued by IRS Exam detailing when compliance is not "substantial" and therefore international information return penalties apply.
August 22, 2017
When "Mostly" is Not Enough Part Two: IRS Issues New Warning to Taxpayers of When Disclosure is Not "Adequate"...
[ read ]
In recent months, the IRS has fired two separate shots across the proverbial bow, highlighting the dangers of "incomplete" or "inadequate" reporting as it relates to imposition of penalties and the elongation of the statute of limitations. This blog post explores a Legal Advice memorandum wherein the IRS ruled that a gift tax return did not adequately disclose a gift and therefore the return did not start limitations period.
August 21. 2017
"Are Public Leaks Enough for the Higher OVDP Penalty?" on August 21, 2017. Click HERE to read the full article.... [ read ]
August 18, 2017
"Swiss Firm's Tax Pact Signal to U.S. Clients Hiding Money Abroad."... [ read ]
August 18, 2017
TSCPA Advanced Estate Planning Conference... [ read ]
August 18, 2017
SBOT Advanced Tax Law Course... [ read ]
August 17, 2017
State Bar of Texas Advanced Tax Law... [ read ]
August 17, 2017
"Doctor fights for return of Tyrannosaurus bataar skull."... [ read ]
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