Josh Ungerman was quoted in the Wall Street Journal article, “The $26 Million Question: What Happens if You Don’t File Your Taxes for a Decade?” This article discusses the penalties and interest that will...
Newly-Announced IRS Audit Campaigns Continue Trend of IRS Enforcement in the Areas of International and Captive Insurance
April 17, 2019
Newly-Announced IRS Audit Campaigns Continue Trend of IRS Enforcement in the Areas of International and Captive Insurance The IRS Large Business and International (LB&I) division – which serves corporations, subchapter...
The IRS Private Letter Ruling: When 100% Tax Certainty (or 100% Tax Relief) is a Must
April 17, 2019
The IRS Private Letter Ruling: When 100% Tax Certainty (or 100% Tax Relief) is a Must A structured transaction with lots of zeros behind the dollar sign? A fatal planning misstep discovered too little too...
IRS Completes Two-Week Blitzkrieg on Employment Tax Noncompliance, with More Action to Come
April 16, 2019
The Internal Revenue Service just announced the results of a national two-week campaign to combat employment tax crimes featuring visits to nearly 100 businesses showing signs of potential serious noncompliance and taking...
The IRS just won its third consecutive battle in its war against Section 831(b) microcaptive arrangements with the Tax Court’s decision in Syzygy Ins. Co., et al vs. Commissioner released on April 10, 2019....