On July 2, 2018, the Large Business and International (LB&I) Division of the IRS released five additional Compliance Campaigns. Initially announced in January 2017, LB&I’s Compliance Campaigns are designed as an issue-based approach to address areas of tax that the Service has identified as having a high risk of compliance issues. This determination is based on
Read MoreSupreme Court Issues Monumental Sales Tax Decision Involving Online Retailers
July 9th, 2018
On June 21, the US Supreme Court issued its decision in South Dakota v. Wayfair, clearing the path for states to impose sales tax on online and remote retailers. Previously it had long been established that a state could not impose a sales tax on a remote seller if they did not have a physical
Read MoreTax Court Follows Avrahami Analysis in Reserve Mechanical Decision
June 22nd, 2018
Last August, the US Tax Court issued its decision in Avrahami v. Comm’r of Internal Revenue, No. 17594-13, (T.C. Aug. 21, 2017), the earliest Tax Court opinion involving a micro-captive. A second case has joined its ranks. On June 18, the Tax Court released its ruling in Reserve Mechanical v. Comm’r of Internal Revenue, No.
Read MoreEarly 2018 is LB&I’s Campaign Season
June 4th, 2018
On May 21, 2018, the Large Business and International (LB&I) Division of the IRS released six additional Compliance Campaigns. Initially rolled out in January 2017, LB&I’s Compliance Campaigns are designed as an issue-based approach to address areas of tax that the Service has identified as having a high risk of compliance issues. This determination is
Read MoreCracking Down on Cryptocurrency
May 29th, 2018
While there are many reasons for people to invest in any given financial platform, the attraction of investing in cryptocurrency has long been rooted in the platform’s anonymity, lack of oversight, and inherent decentralization. As such, many investors, relying on the anonymous and unregulated nature of cryptocurrency, have not reported their earnings to the IRS
Read MoreCryptocurrency Creating Taxpayer Conundrums
April 18th, 2018
As the tax season winds to a close, tax practitioners and taxpayers can once again begin the process of looking ahead. However, this tax filing season has left several questions unanswered. In particular, the treatment of certain cryptocurrency transactions have left taxpayers searching for answers without a clear path forward. Generally, the basic tax treatment
Read MoreSpending Bill Makes Major Changes to Captive Insurance Rules
March 27th, 2018
On March 23, the President signed into law H.R. 1625. This legislation, also known as the “Consolidated Appropriations Act, 2018,” provides appropriations for the Federal Government through Sept. 30, 2018. However, H.R. 1625 also retroactively amends IRC § 831(b), by making changes to the diversification requirements imposed by the PATH Act of 2015. The Path
Read More
