A recently filed Tax Court case has revealed just how much disdain the IRS has for microcaptives. And it is a lot. The case is SCC Holding Company of Pinellas, Inc. v. Commissioner, Docket No. 16285-22, filed in...
Category: Blog
IRS Confirms 2023 Indexed Amounts
October 19, 2022
By Eric D. Marchand, Blog
Our wealth transfer tax system provides taxpayers with exclusions from certain taxes. These exemptions are adjusted annually; the amount of the adjustment is tied to the Consumer Price Index. Last month, I wrote a blog...
The IRS Makes it Easier and Cheaper to Fix Foot Faults on S-Corp Elections
October 18, 2022
By Joel N. Crouch, Blog
During my career, I have assisted a number of taxpayers who have inadvertently terminated an S-Corporation election. Historically, fixing an inadvertent termination has been time consuming and expensive. The IRS fee for a...
IRS Successfully Stifles Taxpayer’s Effort for Judicial Review of IRS Cryptocurrency Guidance
October 4, 2022
The IRS is a bit thin-skinned when it comes to the income taxation of cryptocurrency transactions. While it zealously advocates the legal soundness and correctness of its views, the IRS is just not ready for criticism –...
Go, Hedgie, Go: Hedge Fund challenges IRS’ Position on Limited Partner Exception to Self-Employment (SE) Tax
October 4, 2022
The tax community has been searching for a mighty torch bearer to challenge the IRS’ position that a limited partner cannot wear two hats: one, as a service provider that receives guaranteed payments subject to...