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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...

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...

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...

The Tax Court has delivered its long-awaited decision in Avrahami v. Commissioner, which represents the first court decision – ever – addressing an IRS challenge to a microcaptive insurance arrangement. Not only did...