Notice 2016-66: IRS Offers Settlement for Mirco-captive Insurance Schemes

The Internal Revenue Service announced the mailing of a time-limited settlement offer for certain taxpayers under audit who participated in abusive micro-captive insurance transactions. Taxpayers eligible for this offer will be notified by letter with the applicable terms. Taxpayers who do not receive such a letter are not eligible for this resolution. Abusive micro-captives have been … Continue reading Notice 2016-66: IRS Offers Settlement for Mirco-captive Insurance Schemes

Bloomberg Tax & Accounting Releases Free Special Report Detailing 2020 Projected U.S. Tax Rates

Bloomberg Tax & Accounting has released its free report: 2020 Projected U.S. Tax Rates, ahead of the IRS’s official figures. The report gives tax practitioners and financial professionals an early start on 2020 tax year planning to more effectively develop money-saving strategies for their clients. The more than 500 figures from over 60 IRC sections contained in … Continue reading Bloomberg Tax & Accounting Releases Free Special Report Detailing 2020 Projected U.S. Tax Rates

KPMG: U.S. Congress back in session, possible tax agenda (Sept. 10, 2019)

KPMG has issued a report that analyzes potential tax legislation in the Fall of 2019. The executive summary of the report is as follows: Executive Summary Although there’s a possibility that some tax legislation that has broad bipartisan support in both the House and the Senate could move forward on its own, the best chance … Continue reading KPMG: U.S. Congress back in session, possible tax agenda (Sept. 10, 2019)

Deloitte IRS Insights September 2019: Taxpayer First Act Provisions; No Reasonable Cause for Failure to File for Reliance on Tax Preparer to E-File; and More

Select Provisions of Interest in the Taxpayer First Act Taxpayer First Act, H.R. 3151 was signed on July 1, 2019 summarizing provisions relating to the establishment of an Independent Office of Appeals, sensible enforcement of the IRC, the organization and modernization of the IRS, IRS’s use of information technology, cybersecurity and identity theft protection, the … Continue reading Deloitte IRS Insights September 2019: Taxpayer First Act Provisions; No Reasonable Cause for Failure to File for Reliance on Tax Preparer to E-File; and More

IR-2019-151: IRS announces new procedures to enable certain expatriated individuals a way to come into compliance with their U.S. tax and filing obligations

 The Internal Revenue Service has announced new procedures that will enable certain expatriated individuals who relinquished their U.S. citizenship to come into compliance with their U.S. tax and filing obligations and receive relief for back taxes. The Relief Procedures for Certain Former Citizens apply only to individuals who have not filed U.S. tax returns as U.S. citizens … Continue reading IR-2019-151: IRS announces new procedures to enable certain expatriated individuals a way to come into compliance with their U.S. tax and filing obligations

US v. Schwarzbaum: $15 Million + FBAR Penalties Not Time Barred in Summary Judgment Motion

The US District Court for the Southern District of Florida rejected the summary judgment motion of the taxpayer claiming that the $15 million plus FBAR penalties assessed against him should be set aside because they were time barred.  Click US v. Schwarzbaum to see Summary Judgment Order. See also detailed summary of case by Golding … Continue reading US v. Schwarzbaum: $15 Million + FBAR Penalties Not Time Barred in Summary Judgment Motion

IRC 264 – Is there a deduction loophole? Advisory Alert for Attorneys and Accountants

By Guy Baker and Stanley Mountford The insurance industry is one of the most creative and adaptive group of marketers and agents ever assembled. But they must adhere to the tax laws and respect the intent of the law. A popular strategy has been circulated recently that flies in the face of legal precedence and … Continue reading IRC 264 – Is there a deduction loophole? Advisory Alert for Attorneys and Accountants