The IRS has been aggressively pursing taxpayers operating section 831(b) captives for several years, and it has been successful in its Tax Court litigation.
The IRS’s success in the courtroom has translated to success in audits as it essentially forces taxpayers to either concede or litigate with little opportunity for a resolution somewhere in between.
As part of the announcement, the IRS publicised that nearly 80% of taxpayers offered its settlement initiative (a 90% taxpayer concession) have accepted it.
Lance can and will help!