New IRS Notice Urges Taxpayers to Exit Abusive Micro Captives
PDF Version Notes from the Trenches[1] New IRS Notice Urges Taxpayers to Exit Abusive Micro Captives By Michael E. Lloyd, […]
Captive Update
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Bad Facts Result in Another IRS Captive Win – the Caylor Case
Downloadable Copy Click Here Notes from the Trenches[1] Bad Facts Result in Another IRS Captive Win – the Caylor Case […]
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IRS Announces Second Captive Settlement Initiative
Printable PDF File Format CLICK HERE Notes from the Trenches[1] IRS Announces Second Captive Settlement Initiative By Michael E. Lloyd, […]
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Notes from the Trenches IRS Sends Warning Letter to Captives
Printable PDF Version Click Here Notes from the Trenches[1] IRS Sends Warning Letter to Captives By Michael E. Lloyd, Esq. […]
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Notes from the Trenches Advice for Section 831(b) Captives Who Are Not Under Audit (Yet)
Printable PDF Version Click Here Notes from the Trenches[1] Advice for Section 831(b) Captives Who Are Not Under Audit (Yet) […]
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IRS Takes Next Step on Abusive Micro-Captive Transactions – News Release 2020-26 1/31/20
On 1/31/20, the IRS published News Release 2020-26, describing the next steps on its plan of action against abusive micro-captive […]
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Sea Nine FAQs Posted in Response to Legal Developments
In response to recent developments in the U.S. government’s suit to enjoin the promotion of the Sea Nine VEBAs, Williams Coulson […]
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IRS Audits Employers in Greater Metropolitan Single Employer Plan
Williams Coulson is representing many taxpayers who are or were participants in the Greater Metropolitan Single Employer 419 Plan. The […]
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Sea Nine Defendant provides customer list to IRS
Mr. Sarva sent notices to some or all participating employers in the Sea Nine VEBA informing them that “your participation […]
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Government Seeks Permanent Injunction Against Sea Nine Promoters
On October 9, 2013, United States Attorneys for the Central District of California and the United States Department of Justice […]
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Do I have to file IRS Form 8886 with my 2013 Tax Return?
Any taxpayer participating in a multiple or single employer 419 plan or a 79 plan using cash value life insurance […]
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6707A FAQs
Q1. What is the 6707A penalty? A1. The 6707A penalty (also referred to as the “non-reporting penalty”) is a civil […]
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IRS to Audit Sea Nine VEBA Participating Employers
Williams Coulson tax attorney Mike Lloyd to discuss IRS audit of Sea Nine participating employers In recent months, Williams Coulson […]
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Failing to File Form 8886 for VEBAs like Sea Nine VEBA create multiple penalties.
Taxpayers who participate in 419A(f)(6) multiple employer plans like the Sea Nine VEBA are often very discouraged to find the […]
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IRS Issues Final Sec. 6707A Regulations
On September 2, 2011, the IRS issued final regulations concerning the section 6707A penalty. Such a penalty is imposed on […]
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Ignorance of Listed Transaction Requirement provides no relief to 6707A penalty for 419 Taxpayers.
Williams Coulson receives many calls from taxpayers who are contesting non-reporting penalties (6707A) for failure to file IRS Form 8886 […]
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Sea Nine VEBAs under attack by IRS
We have received numerous calls from taxpayers who are under audit with the IRS with respect to their participation in […]
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Tri State Tax Conference Presentation Interview with Michael Lloyd, Esq.
June 15, 2011 “IRS Attacks Welfare Benefit Plans – A Practitioner’s Guide to Protecting Taxpayers”© Question. How many taxpayers have […]