Transactions of Interest v. Listed Transactions – What is the Difference?
Transactions of Interest v. Listed Transactions – What is the Difference? By Michael E. Lloyd IRS Notice 2016-66. […]
Legal Updates
-
-
Help — My Captive is a Transaction of Interest! – What Does it Mean?
Help — My Captive is a Transaction of Interest! – What does it mean? By Michael E. Lloyd, Esq. […]
-
Good News from the IRS
On August 24, 2016 the IRS released new guidance that allows individuals that have missed the 60 day time limit […]
-
The IRS is Auditing Captives!
The IRS is Auditing Captives! May 26, 2016 Williams Coulson attorneys are currently representing Captive owners who are under […]
-
DELAWARE HOLDING COMPANIES: RIP?
The use of captive intangible companies, commonly referred to as Delaware holding companies, has been a common state tax planning […]
-
Does My Captive have Red Flags?
Captive insurance companies are a common business tool used by thousands of large and small employers to manage various insurance […]
-
12/10/15 – New Captive Proposed Legislation in Tax Extenders Bill.
The House Ways and Means Committee has proposed a Tax Extenders Bill that provides new legislation on Captive Insurance Companies […]
-
Captive Insurance added to IRS “Dirty Dozen” Tax Scams for 2015
Each year, the IRS publishes its “Dirty Dozen” list of Tax Scams for the tax filing season. The purpose is […]
-
Help! My Captive Insurance Company is Under IRS Audit.
We have learned from discussions with IRS Representatives that the IRS is now opening a large number of captive audits. […]
-
IRS Audits Captive Owners – Know the Red Flags!
The IRS is currently auditing owners of captive insurance companies who are customers of promoters who are under scrutiny by […]
-
2015 Retirement Plan Cost of Living Adjustments Announced by IRS
The IRS released the 2015 Cost of Living Adjustments for various limitations affecting retirement plans on October 23, 2014. The […]
-
Recent Tax Court Cases Offer Guidance for Planners When Structuring Private Annuities and Self-Canceling Installment Notes
Daniel P. Johnson and Edward P. Wojnaroski, Jr., members of the Pittsburgh law firm, Williams Coulson Johnson Lloyd Parker & […]
-
Estate Plan Checkup for September: What is the Difference between a Power of Attorney and a Guardianship?
A Power of Attorney document grants to another person (the Agent) the power to act on someone else’s behalf (the […]
-
Proposed Pennsylvania Legislation Would Close Delaware Loophole
Legislation has recently been introduced that would make significant changes to the Pennsylvania corporate net income tax. If enacted, House […]
-
Pennsylvania Enhances KOZ Programs
Recently enacted legislation expands opportunities for securing tax benefits under the Pennsylvania Keystone Opportunity Zone program and related programs (Keystone […]
-
IRS Updates Sections of Internal Revenue Manual Concerning 6707A
On May 16, 2012 the IRS revised the sections of the Internal Revenue Manual dealing with the 6707A penalty. The Manual […]
-
IRS Wins FBAR Case
Fourth Circuit Overturns Taxpayer Victory, Imposes Willful Failure to File Civil Penalty Late last week, the Fourth Circuit issued an […]
-
FBAR FAQs
Q. What is an FBAR and When is it Due? A. An FBAR is a Report of Foreign Bank and […]
-
Taxpayer Advocate Takes IRS to Task on FBAR Disclosure Initiative
In her recently-released annual report to Congress, IRS Taxpayer Advocate Nina E. Olson called for the IRS to improve its […]
-
Estate Plan Checkup For July
DON’T FORGET CRUMMEY RESPONSIBILITIES Many clients have been given copies of “Crummey” letters to send to trust beneficiaries who have […]