On Friday, April 21, a District Court judge denied a taxpayer’s request Summary Judgement for a preliminary injunction to prohibit the IRS from enforcing the disclosure requirements set forth in Notice 2016-66. The Court’s ruling comes on the heels of the May 1st disclosure deadline the IRS has imposed on IRC § 831(b) captive insurance

Steven Miller, alliantgroup’s National Director of Tax, presented on a panel with a current IRS executive to discuss current IRS enforcement initiatives. Key areas of focus were on the newly announced IRS audit campaigns, examination procedures, and the rebirth of reportable transactions and transactions of interest reporting. Russell was joined by members of the Treasury

Earlier this month, Kathy Petronchak, alliantgroup’s Director of IRS Practice & Procedure and the former IRS Commissioner of the Small Business/Self-Employed (SB/SE) Division, was quoted in Tax Notes regarding a letter from the IRS Office of Appeals. The letter from Appeals Chief Kirsten Wielobob clarified four specific procedural changes that were recently implemented and provided

On November 4, alliantgroup’s National Director of Tax and former IRS Acting Commissioner Steven Miller was quoted in the Daily Tax Report regarding a notice from the Service with respect to a significant number of micro-captive insurance arrangements. In Allyson Versprille’s article “Is ‘Micro-Captive’ Insurer Guidance the IRS’s Nuclear Option” Versprille discusses the notice released

Final Regulations for Internal-Use Software Light on Changes, Remain Taxpayer-Friendly Dean Zerbe, alliantgroup’s National Managing Director and the former Senior Counsel to the U.S. Senate Finance Committee, was quoted in Tax Notes regarding the release of internal-use software final regulations for the R&D Tax Credit on October 3. In Andrew Velarde’s article “Internal-Use Software Final

The First Circuit Court of Appeals in Louisiana has handed a small victory to businesses who claim the Louisiana Research and Development Tax Credit. Promyse Prosthetics is a small home grown business that provides custom orthotics and prosthetics to kids and veterans. They applied for state research and development tax credits and were denied after

By Steven Miller, former IRS Acting Commissioner and alliantgroup National Director of Tax On June 1, 2016, in MOUNTANOS v. COMMISSIONER, No. 14-71580, 2016 WL 3079688, at *1 (9th Cir. June 1, 2016), the Ninth Circuit, in an unpublished, three page opinion, affirmed the Tax Court’s decision to disallow a charitable contribution deduction for the