Zobrazeno 1 - 9
of 9
pro vyhledávání: '"Beckett G. Cantley"'
Autor:
Geoffrey Dietrich, Beckett G. Cantley
Publikováno v:
SSRN Electronic Journal.
Since the beginning of his candidacy, there have been demands for President Donald J. Trump’s tax returns. Since his election, there have been non-stop court battles over his refusal to release personal financial information. Several House Committe
Autor:
Geoffrey Dietrich, Beckett G. Cantley
Publikováno v:
SSRN Electronic Journal.
The Bankruptcy Abuse Prevention & Consumer Protection Act (“BAPCPA”), enacted in 2005, overhauled the Bankruptcy Code with the goal of reducing serial filers’ abuse of the bankruptcy system and to increase fairness to both debtors and creditors
Autor:
Geoffrey Dietrich, Beckett G. Cantley
Publikováno v:
SSRN Electronic Journal.
Following several IRS victories against abusive captive insurance companies (“CICs”), the IRS on September 15, 2019 announced a pilot Captive Insurance Company Settlement Initiative (“SI”). The SI set forth a settlement offer to a very limite
Autor:
Geoffrey Dietrich, Beckett G. Cantley
Publikováno v:
SSRN Electronic Journal.
This article seeks to address how general judicial anti-avoidance law may be applied to estate planning with IRC 831(b) captive insurance companies.
Autor:
Beckett G. Cantley, Geoffrey Dietrich
Publikováno v:
SSRN Electronic Journal.
Following its recent success against syndicated conservation easements (“SCEs”), the IRS announced a Settlement Initiative (“SI”) on June 25, 2020 to “bring finality” to taxpayers battling the IRS on SCE issues. The IRS has been suspiciou
Autor:
Beckett G. Cantley, Geoffrey Dietrich
Publikováno v:
SSRN Electronic Journal.
This article is intended to provide a basic set of frequently asked questions on captive insurance companies. The questions are in no way meant to be exhaustive on the subject, but rather solely cover certain basic uniform questions potential captive
Autor:
Beckett G. Cantley, F. Hale Stewart
Publikováno v:
SSRN Electronic Journal.
This is the third article in a series briefly explaining the history of U.S. captive insurance law. In the first article, we noted that businesses can be forced to form their own insurance companies if they cannot obtain insurance or if the only avai
Autor:
F. Hale Stewart, Beckett G. Cantley
Publikováno v:
SSRN Electronic Journal.
After several courts held for the IRS in captive insurance cases and denied the deductibility of premium payments, taxpayers started winning. This article discusses how those taxpayer victories validated captive insurance arrangements and showed that
Autor:
Beckett G. Cantley
Publikováno v:
SSRN Electronic Journal.
The Internal Revenue Service and U.S. Department of Justice have been conducting a nearly decade-long crackdown on tax avoidance activities of U.S. citizens doing business internationally. The offshore crackdown began with hearings conducted by the U