The current insurance market has become difficult for everyone involved. Insurers are withdrawing from entire markets. Fewer insurers are offering quotes on applications while underwriters are asking for additional information as part of the application process. Reinsurers are tightening underwriting standards, further constricting coverage. Read full article >>
Specialists in Tax Litigation
News
Is Winter Coming for Asset Management Firms and Service Providers? The IRS signals its Intent to Increase Audits of Large Partnerships.
The IRS recently announced its plan to utilize its Inflation Reduction Act funding to shift its enforcement efforts on a certain subset of filers in an attempt to “restore fairness in tax compliance.” One such subset of filers specifically mentioned in the bulletin are large complex partnerships, of the type commonly seen in the various…
IRS and Delaware Department of Insurance Settle Litigation, but Questions Pertaining to McCarran Ferguson Remain
The Delaware Department of Insurance (DDOI) recently announced it appealed the Third Circuit’s decision in United States of America v. Delaware Department of Insurance, which involved the application of the McCarran Ferguson Act (MFA) to an IRS summons. The plot thickened on July 26 after Judge Alito requested briefing on the issue. The story abruptly…
California Begins Coordinated Enforcement Action Targeting 831(b) “Microcaptive” Insurance Companies–Imposes November Deadline for Self-Enforcement
By Matt Spradling and Hale Stewart The State of California recently released FTB Notice 2023-02, which announced the Franchise Tax Board’s creation of a “resolution process” enabling certain taxpayers to resolve specific transactions that are possibly subject to the non-economic substance transaction (“NEST”) understatement penalties. Taxpayers must decide whether to voluntarily amend returns and unwind…
ZMF is Victorious at the Courthouse on 179D Case
This week, the U.S. Tax Court, in a unanimous TC opinion, affirmed ZMF client’s entitlement to the 179D energy-efficient commercial building tax deduction in Johnson v. Commissioner. Not only was the deduction affirmed, but the Court agreed with every legal argument made by the ZMF team and rejected the IRS’s arguments in totality. The Court…
