Resources

The IRS has officially declared war on small captive insurance arrangements that rely on I.R.C. Section 831(b) and the ability of the captive to exclude from income a certain amount of premiums earned each year. In Notice...

Growing up my Mom used to say “You’ve made your bed, now lie in it.” Luckily for taxpayers, my Mom is not the IRS. The IRS understands that mistakes happen, conditions change, and deals sour. Under the rescission...

Effective October 1, 2016, the IRS has revised the Internal Revenue Manual (IRM) instructing Appeals Officers that most Appeals conferences will be held by telephone instead of in person. The changes to the IRS are in...

In recently issued Revenue Procedure 2016-49, the Service has confirmed that both a QTIP election and a portability election may be made on the same estate tax return, thereby maximizing exemption planning and flexibility in...

As I discussed in detail in my August 4, 2016 blog post, “Without Further Ado, The Proposed Regulations Under Section 2704”, the new proposed regulations are undoubtedly controversial. In their current form,...