On June 18, 2017, the Tax Court issued its opinion in Reserve Mechanical Corp. v. Comm'r, a case involving a microcaptive insurance company.
On August 21, 2017, the Tax Court issued its opinion in Avrahami v. Comm'r, a case of first impression relating to the taxpayers' use of a microcaptive insurance company.
The Internal Revenue Service (IRS) Large Business & International Division (LB&I) is transitioning to a centralized compliance and examination process that focuses on issue-based campaigns.
Over the past decade, the U.S.
On April 23, 2015, the Treasury Department (Treasury) and Internal Revenue Service (IRS) issued proposed regulations on the application of the passive foreign investment company (PFIC) rules of Int
Today the IRS released materials regarding the new reporting requirements for uncertain tax positions (UTPs).1 These materials (available through the links below) include:
Major changes to the tax rules governing nonqualified deferred compensation are now close to passage by Congress as part of its consideration of legislation to repeal the U.S.
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