By: Randall P. Andreozzi, Esq. In 2016 the IRS issued Notice 2016-66, which identifies certain micro captive insurance transactions as potentially abusive. The Notice generally describes the abusive arrangement as one where owners of closely-held entities engage in a captive insurance arrangement that purports to ensure against certain risks associated with the business. The business pays “premiums” to the captive
By: Randall P. Andreozzi, Esq. Cryptocurrency investors be warned. The IRS is coming for you. Over the course of several years, the IRS has methodically ramped up its efforts to tackle the burgeoning cryptocurrency market. As taxpayers enter this market, it’s important that they understand that virtual currency transactions are taxable events involving actual assets and that the IRS treats
By: Randall P. Andreozzi Things are emerging from the abyss that is the longest government shutdown in United States history. Yes, there exist some things so resilient, so pervasive, so constant they can survive and proliferate even in a governmental vacuum. Our friends who are U. S. citizens living abroad know this species all too well and are likely collectively
By: Randall P. Andreozzi, Esq. The IRS announced on Wednesday that it will officially end the 2014 Offshore Voluntary Disclosure Program (affectionately known to practitioners as the “OVDP”) on September 28, 2018. The Agency urged taxpayers who still have not come forward to do so before the program ends. The 2014 OVDP is the last evolution of the program IRS
In a court-reviewed opinion published on January 29, 2018, the U.S. Tax Court in Coffey, et. al. v. Commissioner, 150 T.C. No. 4, found in favor of the taxpayers and dismissed the Internal Revenue Service’s Statutory Notices of Deficiency against them as time barred. Andreozzi Bluestein LLP represented the Petitioners in this case before the Tax Court. The Petitioners claimed
By: Justin J. Andreozzi, J.D.; Randall P. Andreozzi, J.D.; and Arlene Hibschweiler, MBA, J.D. While at one time, the IRS would discontinue a civil examination when it began a criminal investigation of a taxpayer, it is now the IRS’s policy in certain situations to conduct simultaneous civil and criminal investigations in what are called parallel investigations. While, technically, the civil
By: Randall P. Andreozzi Recent revisions to the IRS Offshore Voluntary Disclosure Programs illustrate that the Service is becoming more aggressive and less tolerant with those taxpayers who have not yet come forward to report their interests in foreign bank accounts. The IRS on June 18, 2014, published new Streamlined Filing Compliance Procedures. The new Programs – one for U.S.