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Searching Content indexed under Tax by Elizabeth Erickson ordered by Published Date Descending.
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IRS Identifies Certain 831(b) Captives As "Transactions Of Interest"
In Notice 2016-66, the Treasury Department and the IRS identified a particular § 831(b) "micro-captive" transaction as a "transaction of interest"...
United States
17 Nov 2016
2
IRS And Treasury Release Update To 2016-2017 Priority Guidance Plan
The US Department of the Treasury and IRS issue Priority Guidance Plans each year to identify and prioritize the tax issues they believe should be addressed through regulations...
United States
10 Nov 2016
3
IRS Updates Rules Regarding Appeals Conferences
The Internal Revenue Service (IRS) has revised the Internal Revenue Manual (IRM) regarding Appeals Conferences. Below is a summary of material changes to IRM 8.6.1, effective October 1, 2016:
United States
26 Sep 2016
4
IRS Issues New Procedures To IRS Appeals For Requesting Assistance From Exam In Docketed Tax Court Case
Under the new procedures, Appeals will send a request for Exam's assistance if Appeals determines that the new information merits additional analysis or investigation.
United States
4 Jul 2016
5
U.S. Tax Court Upholds Favorable Definition Of Insurance
R.V.I. Guaranty Co. Ltd. (RVIG), is a Bermuda corporation registered and regulated as an insurance company under the Bermuda Insurance Act of 1978.
United States
16 Dec 2015
6
Distinguishing Between Captive Insurance And Related Party Derivatives: Chief Counsel Advice Memorandum 201511021
The Taxpayer Group in the CCA is described as a group of related entities engaged in the design, manufacture, etc., of products and services in the environmental and life sciences sectors.
United States
23 Jun 2015
7
The New Section 6501(c)(10) Regulations
Under § 6501(a), the IRS generally has three years from the date a tax return is filed to assess additional tax.
United States
24 Apr 2015
8
Captive Insurance Litigation: Key 2014 Cases
In 2014, the U.S. Tax Court issued two opinions with significant implications in the captive insurance world. On January 14, 2014, the court issued a reviewed decision in Rent-A-Center, Inc. v. Commissioner.
United States
16 Apr 2015
9
IRS Clarifies Requirements For Establishing Non-Willful Conduct In Offshore Disclosure Cases
Voluntary disclosure programs exist for taxpayers that are not in compliance with their tax and information reporting obligations with respect to foreign bank accounts and assets.
United States
3 Feb 2015
10
IRS Rules Captive Reinsurance Arrangement Involving Retiree Medical Benefits Qualifies As Insurance For Federal Tax Purposes
An employer’s wholly owned captive insurance subsidiary could reinsure the employer’s retiree medical benefit risks and still qualify as insurance for federal tax purposes.
United States
4 Jun 2014
11
Second Circuit Disagrees With Claims Court And Denies Deduction For Contingent Dividend Liability
On August 1, 2013, the U.S. Court of Appeals for the Second Circuit held in New York Life Ins. Co. v. U.S., that the taxpayer’s liability for policyholder dividends was contingent, and therefore, was not deductible until the taxpayer paid them.
United States
13 Aug 2013
12
IRS Provides Guidance On The Taxation Of Employment-Related Settlement Payments
In an internal memorandum dated October 22, 2008, but released only last week, the Internal Revenue Service (IRS) Office of Chief Counsel has outlined information necessary to determine the correct tax treatment of employment-related settlement payments.
United States
22 Jul 2009
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