The Internal Revenue Service (IRS) began sending contact letters in April reminding certain taxpayers that it has their information relating to deductions claimed for micro-captive insurance arrangements. The letters asked taxpayers who stopped claiming deductions to provide certain information under penalty of perjury, including the final year a micro-captive deduction was claimed. As for those taxpayers continuing to participate in micro-captive insurance transactions, the IRS recommends that the taxpayer consult an independent competent tax advisor on the proper treatment of past and future tax years and consider best options for any improperly claimed deductions, including the filing of amended returns.
These letters followed the IRS announcement in January stating that IRS enforcement activity in this area will be significantly increased. The IRS announcement also warned that examinations impacting micro-captive insurance transactions of several thousand taxpayers will be opened by these teams in the coming months. Potential outcomes can include full disallowance of claimed captive insurance deductions, inclusion of income by the captive entity and imposition of all applicable penalties.
This webinar will guide tax professionals and advisers on critical issues relating to micro-captive insurance transactions and the IRS, including strategies for defending these transactions during the IRS Examination. IRS Appeals and court litigation. For those taxpayers in receipt of the IRS contact letters, the program will also explore what proactive opportunities to take proactive, corrective measures may assist in avoiding onerous examinations and/or steep penalties that could otherwise be asserted.
Steven Toscher is a principal of Hochman, Salkin, Rettig, Toscher & Perez, P.C., specializing in civil and criminal tax litigation. Mr. Toscher is a Certified Tax Specialist in Taxation, the State Bar of California Board of Legal Specialization. He maintains an active practice before the United States Tax Court, the Federal District Courts in California and Nevada, the Ninth Circuit Court of Appeals and the California State Courts. He frequently appears before the Internal Revenue Service, the California Franchise Tax Board and the California State Board of Equalization.
MICHEL R. STEIN is a principal at Hochman, Salkin, Rettig, Toscher & Perez, specializing in tax controversies, as well as tax planning for individuals, businesses and corporations. For almost 20 years, he has represented individuals with sensitive issue civil tax examinations where substantial penalty issues may arise and extensively advised individuals on foreign and domestic voluntary disclosures regarding foreign account and asset compliance matters.
Mr. Stein is well respected for his expertise and judgment in handling matters arising from the U.S. Government’s ongoing enforcement efforts regarding undeclared interests in foreign financial accounts and assets, including various methods of participating in a timely voluntary disclosure to minimize potential exposure to civil tax penalties and avoiding a criminal tax prosecution referral. He has assisted hundreds of individuals who have come into compliance with their foreign reporting requirements through the OVDP, Streamline or otherwise.
Throughout his career, Mr. Stein has represented thousands of individual, business and corporate taxpayers involved in civil examinations and administrative appeals, tax collection matters as well as with possible assertions of fraudulent conduct and in defending criminal tax investigations and prosecutions at every administrative level within the IRS. He has litigated tax cases in the U.S. Tax Court, the U.S. District Court, and various U.S. Circuit Courts of Appeal. He continues to provide tax advice to taxpayers and their advisors around the world.
Mr. Stein is a frequent lecturer at national and regional conferences on topics including tax compliance sensitive issues, IRS examinations, State and Federal worker classification issues, etc. Mr. Stein received his LL.M. in Taxation from the NYU School of Law and graduated from the University of California, Hastings College of the Law. He gained further expertise as Attorney-Adviser to the Honorable Judge Larry L. Nameroff of the U.S. Tax Court. He is a Certified Specialist in Taxation Law by the State Bar of California, Board of Legal Specialization.
Cory Stigile specializes in tax controversies as well as tax, business, and international tax. His representation includes Federal and state tax controversy matters and tax litigation, including sensitive tax-related examinations and investigations for individuals, business enterprises, partnerships, limited liability companies, and corporations. His practice also includes complex civil tax examinations, administrative appeals and tax collection proceedings (where he is widely respected for achieving meaningful resolutions of difficult tax collection issues). Mr. Stigile frequently writes and lectures on topics involving taxation.
His more recent speaking engagements include “Back to Basics on The Ethics of Federal Tax Practice: Best Practices 101” for the American Bar Association Tax Section, “The Administrative Tax Controversy Case from Examination to Appeals” for the ABA Tax Section, “Tax Settlements – IRS Appeals, FTB Settlement Bureau and CDTFA Settlement Section” for the Channel Counties Santa Barbara Discussion Group of CalCPA, “Income Tax Update” for California State University, Los Angeles, “Tax Identity Theft” for the Taxation Technical Committee of the Los Angeles Chapter of CalCPA, “Best Practices in ‘Settling’ Cases with the IRS and FTB for the Glendale Estate Planning Counsel, the “IRS Audit Programs and Other Hot Tax Controversy Issues” for the Santa Clarita Valley Discussion Group of the Los Angeles Chapter of CalCPA, “Updates on Civil and Criminal Tax (Federal) for the Best of CLE program in Santa Monica, California, and the “Tips and Tricks for IRS, FTB & SBE Settlements” panel at the Los Angeles County Bar Association Practitioner’s Conference. He was also interviewed by Bloomberg Law regarding IRS Wealth Squad audits focusing on the super-rich. Mr. Stigile was awarded the distinction of Super Lawyer Rising Star in 2012 through 2016, as recognized and published in Los Angeles Magazine. He is also on the Planning Committee of the Annual UCLA Extension Tax Controversy Institute and a member of the Western States Bar Association.
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