Avrahami v. Commissioner
November 17, 2015
Panelists will summarize the 433 page IRS brief, which provides the IRS' blueprint for attacking what it believes are abusive captive structures. Panelists will also comment on various key issues raised by the IRS, including economic substance, risk distribution, loans, ownership structure, domicile, and the consequences of not qualifying as insurance for Federal tax purposes. As this is only the IRS Answering Brief and not the Tax Court's opinion, panelists will provide perspective and next steps in this important case.
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