Tag Archives: captive insurance

A 360-Degree View: July and August 2017

Wrapping up July—and Looking Forward to August Tax Controversy Activities in August: August 7, 2017: Elizabeth Erickson and Kristen Hazel will be representing McDermott Will & Emery at the 2017 US Captive Awards in Burlington, Vermont. McDermott has been shortlisted in the Law Firm category. August 8, 2017: Tom Jones is presenting an update on … Continue Reading

Run for Cover—IRS Unveils Initial “Campaigns” for LB&I Audits

They’re here!  On January 31, 2017, the Internal Revenue Service (IRS) Large Business & International (LB&I) division released its much-anticipated announcement related to the identification and selection of campaigns.  The initial list identifies 13 compliance issues that LB&I is focused on and lists the specific practice area involved and the lead executive for each campaign.  … Continue Reading

Ax v. Commissioner: The Tax Court Reaffirms that It Is Not Subject to the APA

On April 11, 2016, the US Tax Court issued its T.C. opinion in Ax v. Commissioner.  The notice of deficiency in the case determined that certain premium payments made to a captive insurance company were not established by the taxpayer to be (1) insurance expenses and (2) paid.  But this is not a run of … Continue Reading
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