On November 15, 2023, the Tax Court released its opinion in YA Global v. Commissioner and, among other conclusions, held that YA Global Investments LP, a Cayman Islands.
Micro-captive insurance arrangements are an area of focus for the IRS. As we have discussed in our prior post discussing Avrahami v. Commissioner, 149 T.C. No. 7 (2017), micro-captive insurance arrangements.
Cannabis-based business audits are lucrative for the Internal Revenue Service. IRS auditors are more likely to see returns from cannabis audits than from mainstream industries and.
Although the government bears the burden of production for penalties, this often involves nothing more than showing that the penalties were properly assessed. Penalty relief is usually.