Resources

On November 17, 2016, the Department of Justice filed a petition in a United States District Court in Northern California asking the court to issue a John Doe Summons to Coinbase, the largest bitcoin exchange in the U.S.,...

Josh Ungerman was quoted  in an article in Tax Notes on November 22, 2016, “DOJ Seeks John Doe Summons on Largest U.S. Bitcoin Exchanger.”

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...