Abusive Tax Shelters: Abusive tax structures including trusts and syndicated conservation easements are sometimes used to avoid paying taxes. The IRS Published on February 19, 2020 Edit article View stats call firstStatus is online call first Speaker, author expert witness at VEBA LLC 193 articles Abusive Tax Shelters: Abusive tax structures including trusts and syndicated conservation easements are sometimes used to avoid paying taxes. The IRS is committed to stopping complex tax avoidance schemes and the people who create and sell them. The vast majority of taxpayers pay their fair share, and everyone should be on the lookout for people peddling tax shelters that sound too good to be true. When in doubt, taxpayers should seek an independent opinion regarding complex products they are offered. (IR-2019-47)Abusive Tax Shelters: Abusive tax structures including trusts and syndicated conservation easements are sometimes used to avoid paying taxes. The IRS is committed to stopping complex tax avoidance schemes and the people who create and sell them. The vast majority of taxpayers pay their fair share, and everyone should be on the lookout for people peddling tax shelters that sound too good to be true. When in doubt, taxpayers should seek an independent opinion regarding complex products they are offered. (IR-2019-47)
Abusive Tax Shelters: Abusive tax structures including trusts and syndicated conservation easements are sometimes used to avoid paying taxes. The IRS Published on February 19, 2020 Edit article View stats call firstStatus is online call first Speaker, author expert witness at VEBA LLC 193 articles Abusive Tax Shelters: Abusive tax structures including trusts and syndicated conservation easements are sometimes used to avoid paying taxes. The IRS is committed to stopping complex tax avoidance schemes and the people who create and sell them. The vast majority of taxpayers pay their fair share, and everyone should be on the lookout for people peddling tax shelters that sound too good to be true. When in doubt, taxpayers should seek an independent opinion regarding complex products they are offered. (IR-2019-47)Abusive Tax Shelters: Abusive tax structures including trusts and syndicated conservation easements are sometimes used to avoid paying taxes. The IRS is committed to stopping complex tax avoidance schemes and the people who create and sell them. The vast majority of taxpayers pay their fair share, and everyone should be on the lookout for people peddling tax shelters that sound too good to be true. When in doubt, taxpayers should seek an independent opinion regarding complex products they are offered. (IR-2019-47)
IRS Information Welfare Benefit PlansNotice 2007-83 Abusive Trust Arrangements Utilizing Cash Value Life Insurance Policies Purportedly to Provide Published on February 20, 2020 Edit article View stats call firstStatus is online call first Speaker, author expert witness at VEBA LLC 195 articles IRS Information Welfare Benefit Plans Notice 2007-83
Abusive Trust Arrangements Utilizing Cash Value Life Insurance Policies Purportedly to Provide Welfare Benefits IRS Information Abusive Trust Arrangements
BACKGROUND 1. Promoted Arrangements 2. Intent to Challenge Transactions
Captive Insurance Audit Representation Previously the realm of large corporations, a growing number of mid-sized and small businesses, professional se Published on February 20, 2020 Edit article View stats call firstStatus is online call first Speaker, author expert witness at VEBA LLC 197 articles Captive Insurance Audit Representation Previously the realm of large corporations, a growing number of mid-sized and small businesses, professional service companies, and nonprofit organizations have been taking advantage of domestic and offshore captive insurance arrangements.
Although the establishment and management of a captive insurance company (“captive”) is legal, some have come under IRS scrutiny.
Benefits of captive insurance Captive insurance is a kind of self-insurance company formed to provide coverage for a wide variety of business property and casualty risks. Premiums are not paid to an outside insurance company, but are instead invested and accumulate over time. The funds can later be used to cover losses connected to business risks that are either uninsurable or for which commercial insurance coverage is unreasonably priced.
In addition to the primary benefits related to cash flow and risk management, if a captive has the required economic and business purpose its premiums provide significant tax, estate planning and asset protection benefits. Captives can also provide a company with access to the reinsurance market, which can also provide significant cost savings and an opportunity to make additional profits from insurance sales.
Types of captive insurance Captives take many forms, including pure (single parent), association (group), agency, alien, branch, diversified, reciprocal (risk retention groups), microcaptives, rent-a-captives and special purpose vehicles/reinsurers.Captive Insurance Audit Representation Previously the realm of large corporations, a growing number of mid-sized and small businesses, professional service companies, and nonprofit organizations have been taking advantage of domestic and offshore captive insurance arrangements.
Although the establishment and management of a captive insurance company (“captive”) is legal, some have come under IRS scrutiny.
Benefits of captive insurance Captive insurance is a kind of self-insurance company formed to provide coverage for a wide variety of business property and casualty risks. Premiums are not paid to an outside insurance company, but are instead invested and accumulate over time. The funds can later be used to cover losses connected to business risks that are either uninsurable or for which commercial insurance coverage is unreasonably priced.
In addition to the primary benefits related to cash flow and risk management, if a captive has the required economic and business purpose its premiums provide significant tax, estate planning and asset protection benefits. Captives can also provide a company with access to the reinsurance market, which can also provide significant cost savings and an opportunity to make additional profits from insurance sales.
Types of captive insurance Captives take many forms, including pure (single parent), association (group), agency, alien, branch, diversified, reciprocal (risk retention groups), microcaptives, rent-a-captives and special purpose vehicles/reinsurers.
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syndicated conservation easement transactions Published on February 27, 2020 Edit article View stats call firstStatus is online call first Speaker, author expert witness at VEBA LLC 200 articles The Internal Revenue Service announced today a significant increase in enforcement actions for syndicated conservation easement transactions, a priority compliance area for the agency.
Coordinated examinations are being conducted across the IRS in the Small Business and Self-Employed Division, Large Business and International Division and Tax Exempt and Government Entities Division. Separately, investigations have been initiated by the IRS' Criminal Investigation division. These audits and investigations cover billions of dollars of potentially inflated deductions as well as hundreds of partnerships and thousands of investors.
"We will not stop in our pursuit of everyone involved in the creation, marketing, promotion and wrongful acquisition of artificial, highly inflated deductions based on these aggressive transactions. Every available enforcement option will be considered, including civil penalties and, where appropriate, criminal investigations that could lead to a criminal prosecution," said IRS Commissioner Chuck Rettig. "Our innovation labs are continually developing new, more extensive enforcement tools that employ advanced techniques. If you engaged in any questionable syndicated conservation easement transaction, you should immediately consult an independent, competent tax advisor to consider your best available options. It is always worthwhile to take advantage of various methods of getting back into compliance by correcting your tax returns before you hear from the IRS. Our continued use of ever-changing technologies would suggest that waiting is not a viable option for most taxpayers."
In December 2016, the IRS issued Notice 2017-10 (PDF), which designated certain syndicated conservation easements as listed transactions. Specifically, the Notice listed transactions where investors in pass-through entities receive promotional material offering the possibility of a charitable contribution deduction worth at least two and half times their investment. In many transactions, the deduction taken is significantly higher than 250 percent of the investment. Syndicated conservation easements are included on the IRS's 2019 "Dirty Dozen" list of tax scams to avoid.
"Abusive syndicated conservation easement transactions undermine the public's trust in private land conservation and defraud the government of revenue," Rettig said. "Putting an end to these abusive schemes is a high priority for the IRS."
Taxpayers may avoid the imposition of penalties relating to improper contribution deductions if they fully remove the improper contribution and related tax benefits from their returns by timely filing a qualified amended return or timely administrative adjustment request.
The IRS's comprehensive compliance efforts are focused on the abusive syndicated conservation easement transactions described in Notice 2017-10, recognizing that there are many legitimate conservation easement transactions.
The IRS is fully committed to putting an end to abusive syndicated conservation easement transactions, and holding accountable the individuals and entities who promoted, assisted with or participated in these schemes. The IRS is committing significant examination and investigative resources to vigorously audit the entities and individuals involved in this scheme, including those who failed to properly disclose their partici
Abusive Tax Shelters: Abusive tax structures including trusts and syndicated conservation easements are sometimes used to avoid paying taxes. The IRS
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193 articles
Abusive Tax Shelters: Abusive tax structures including trusts and syndicated conservation easements are sometimes used to avoid paying taxes. The IRS is committed to stopping complex tax avoidance schemes and the people who create and sell them. The vast majority of taxpayers pay their fair share, and everyone should be on the lookout for people peddling tax shelters that sound too good to be true. When in doubt, taxpayers should seek an independent opinion regarding complex products they are offered. (IR-2019-47)Abusive Tax Shelters: Abusive tax structures including trusts and syndicated conservation easements are sometimes used to avoid paying taxes. The IRS is committed to stopping complex tax avoidance schemes and the people who create and sell them. The vast majority of taxpayers pay their fair share, and everyone should be on the lookout for people peddling tax shelters that sound too good to be true. When in doubt, taxpayers should seek an independent opinion regarding complex products they are offered. (IR-2019-47)
Abusive Tax Shelters: Abusive tax structures including trusts and syndicated conservation easements are sometimes used to avoid paying taxes. The IRS
ReplyDeletePublished on February 19, 2020
Edit article
View stats
call firstStatus is online
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Speaker, author expert witness at VEBA LLC
193 articles
Abusive Tax Shelters: Abusive tax structures including trusts and syndicated conservation easements are sometimes used to avoid paying taxes. The IRS is committed to stopping complex tax avoidance schemes and the people who create and sell them. The vast majority of taxpayers pay their fair share, and everyone should be on the lookout for people peddling tax shelters that sound too good to be true. When in doubt, taxpayers should seek an independent opinion regarding complex products they are offered. (IR-2019-47)Abusive Tax Shelters: Abusive tax structures including trusts and syndicated conservation easements are sometimes used to avoid paying taxes. The IRS is committed to stopping complex tax avoidance schemes and the people who create and sell them. The vast majority of taxpayers pay their fair share, and everyone should be on the lookout for people peddling tax shelters that sound too good to be true. When in doubt, taxpayers should seek an independent opinion regarding complex products they are offered. (IR-2019-47)
IRS Information Welfare Benefit PlansNotice 2007-83 Abusive Trust Arrangements Utilizing Cash Value Life Insurance Policies Purportedly to Provide
ReplyDeletePublished on February 20, 2020
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195 articles
IRS Information Welfare Benefit Plans
Notice 2007-83
Abusive Trust Arrangements Utilizing Cash Value Life Insurance Policies Purportedly to Provide Welfare Benefits
IRS Information Abusive Trust Arrangements
BACKGROUND
1. Promoted Arrangements
2. Intent to Challenge Transactions
LISTED TRANSACTIONS
Captive Insurance Audit Representation Previously the realm of large corporations, a growing number of mid-sized and small businesses, professional se
ReplyDeletePublished on February 20, 2020
Edit article
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call firstStatus is online
call first
Speaker, author expert witness at VEBA LLC
197 articles
Captive Insurance Audit Representation
Previously the realm of large corporations, a growing number of mid-sized and small businesses, professional service companies, and nonprofit organizations have been taking advantage of domestic and offshore captive insurance arrangements.
Although the establishment and management of a captive insurance company (“captive”) is legal, some have come under IRS scrutiny.
Benefits of captive insurance
Captive insurance is a kind of self-insurance company formed to provide coverage for a wide variety of business property and casualty risks. Premiums are not paid to an outside insurance company, but are instead invested and accumulate over time. The funds can later be used to cover losses connected to business risks that are either uninsurable or for which commercial insurance coverage is unreasonably priced.
In addition to the primary benefits related to cash flow and risk management, if a captive has the required economic and business purpose its premiums provide significant tax, estate planning and asset protection benefits. Captives can also provide a company with access to the reinsurance market, which can also provide significant cost savings and an opportunity to make additional profits from insurance sales.
Types of captive insurance
Captives take many forms, including pure (single parent), association (group), agency, alien, branch, diversified, reciprocal (risk retention groups), microcaptives, rent-a-captives and special purpose vehicles/reinsurers.Captive Insurance Audit Representation
Previously the realm of large corporations, a growing number of mid-sized and small businesses, professional service companies, and nonprofit organizations have been taking advantage of domestic and offshore captive insurance arrangements.
Although the establishment and management of a captive insurance company (“captive”) is legal, some have come under IRS scrutiny.
Benefits of captive insurance
Captive insurance is a kind of self-insurance company formed to provide coverage for a wide variety of business property and casualty risks. Premiums are not paid to an outside insurance company, but are instead invested and accumulate over time. The funds can later be used to cover losses connected to business risks that are either uninsurable or for which commercial insurance coverage is unreasonably priced.
In addition to the primary benefits related to cash flow and risk management, if a captive has the required economic and business purpose its premiums provide significant tax, estate planning and asset protection benefits. Captives can also provide a company with access to the reinsurance market, which can also provide significant cost savings and an opportunity to make additional profits from insurance sales.
Types of captive insurance
Captives take many forms, including pure (single parent), association (group), agency, alien, branch, diversified, reciprocal (risk retention groups), microcaptives, rent-a-captives and special purpose vehicles/reinsurers.
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syndicated conservation easement transactions
ReplyDeletePublished on February 27, 2020
Edit article
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call firstStatus is online
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Speaker, author expert witness at VEBA LLC
200 articles
The Internal Revenue Service announced today a significant increase in enforcement actions for syndicated conservation easement transactions, a priority compliance area for the agency.
Coordinated examinations are being conducted across the IRS in the Small Business and Self-Employed Division, Large Business and International Division and Tax Exempt and Government Entities Division. Separately, investigations have been initiated by the IRS' Criminal Investigation division. These audits and investigations cover billions of dollars of potentially inflated deductions as well as hundreds of partnerships and thousands of investors.
"We will not stop in our pursuit of everyone involved in the creation, marketing, promotion and wrongful acquisition of artificial, highly inflated deductions based on these aggressive transactions. Every available enforcement option will be considered, including civil penalties and, where appropriate, criminal investigations that could lead to a criminal prosecution," said IRS Commissioner Chuck Rettig. "Our innovation labs are continually developing new, more extensive enforcement tools that employ advanced techniques. If you engaged in any questionable syndicated conservation easement transaction, you should immediately consult an independent, competent tax advisor to consider your best available options. It is always worthwhile to take advantage of various methods of getting back into compliance by correcting your tax returns before you hear from the IRS. Our continued use of ever-changing technologies would suggest that waiting is not a viable option for most taxpayers."
In December 2016, the IRS issued Notice 2017-10 (PDF), which designated certain syndicated conservation easements as listed transactions. Specifically, the Notice listed transactions where investors in pass-through entities receive promotional material offering the possibility of a charitable contribution deduction worth at least two and half times their investment. In many transactions, the deduction taken is significantly higher than 250 percent of the investment. Syndicated conservation easements are included on the IRS's 2019 "Dirty Dozen" list of tax scams to avoid.
"Abusive syndicated conservation easement transactions undermine the public's trust in private land conservation and defraud the government of revenue," Rettig said. "Putting an end to these abusive schemes is a high priority for the IRS."
Taxpayers may avoid the imposition of penalties relating to improper contribution deductions if they fully remove the improper contribution and related tax benefits from their returns by timely filing a qualified amended return or timely administrative adjustment request.
The IRS's comprehensive compliance efforts are focused on the abusive syndicated conservation easement transactions described in Notice 2017-10, recognizing that there are many legitimate conservation easement transactions.
The IRS is fully committed to putting an end to abusive syndicated conservation easement transactions, and holding accountable the individuals and entities who promoted, assisted with or participated in these schemes. The IRS is committing significant examination and investigative resources to vigorously audit the entities and individuals involved in this scheme, including those who failed to properly disclose their partici