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By on October 26, 2017
Statistics show that IRS Criminal Enforcement is down. But it is certainly not out. Seemingly adopting the mantra "quality not quantity," earlier this year the IRS Criminal Investigations division announced the creation of two new nationally-coordinated investigation units that, according to statements made this week, the IRS expects will be fully operational in January 2018.
By on October 17, 2017
The Tax Court's decision in Avrahami v. Commissioner created a storm that is brewing in the I.R.C. Section 831(b) micro-captive insurance industry. Some microcaptives are a safe distance away from the storm's path. Others are at risk for an indirect hit. Still others are likely facing the very eye of the storm. The key is preparation, and this requires an objective assessment. We must know where the captive insurance planning sits on the storm's projected path so we can help our clients make the planning storm-ready. As we begin to look more closely at our clients' captive insurance planning in light of Avrahami, we should be mindful of the following warning signs:
"Qualifying" Your Settlement Offer: How to Get the IRS to Think Twice Before Rejecting a Fair Offer
By on October 16, 2017
With funding and staffing low, and caseloads high, you would expect the IRS to be more attentive in its efforts to resolve cases. But in my experience the opposite holds true, with IRS personnel seemingly more interested in moving a case to someone else's desk rather than out the door. So how do you get the IRS to seriously consider an otherwise fair settlement offer? Make it a qualified offer.
Options for Taxpayers With Unfiled Tax Returns
By on October 11, 2017
Whether due to oversight or intentional conduct, there are number of individuals and businesses with unfiled federal tax returns. Under the Internal Revenue Code (IRC) the failure to file a tax return is a misdemeanor (IRC Section 7203) punishable by imprisonment of not more than one year and a fine of up to $25,000.
Treasury and IRS to Withdraw Controversial 2704 Proposed Regulations
By on October 4, 2017
The long, tumultuous road of the proposed regulations under I.R.C. Section 2704 (the "2704 Proposed Regulations") should be coming to an end with Treasury's recent report in response to Executive Order 13789.
TIGTA Report on IRS Estate and Gift Tax Examinations
By on October 2, 2017
On September 28th, the Treasury Inspector General of Tax Administration (TIGTA) issued a report recommending changes to fix the procedures the IRS uses to select estate and gift tax returns for examination.