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Issue Number: 2019-34
Inside This Issue
- Settlement Offer for Micro-Captive Insurance
- Preparing Your Client for Assistance after a
- Help Your Clients Understand IRS Notices
- Technical Guidance
1. Settlement Offer for Micro-Captive Insurance
The IRS this week announced
a time-limited settlement offer for certain taxpayers under audit who
participated in abusive micro-captive insurance transactions. Following
wins in three recent U.S. Tax Court cases, the IRS has decided to offer
settlements to taxpayers currently under exam and began sending notices to
approximately 200 taxpayers. Taxpayers eligible for this offer will be
notified by letter with the applicable terms.
"The IRS is taking this step in the interests of sound tax
administration," IRS Commissioner Chuck Rettig said. "We
encourage taxpayers under exam and their advisors to take a realistic look
at their matter and carefully review the settlement offer, which we believe
is the best option for them given recent court cases. We will continue to
vigorously pursue these and other similar abusive transactions going
2. Preparing Your Client for Assistance after a
Disaster can strike
without warning, causing damage and destruction. But before the IRS can
authorize tax relief, the President must declare a federal disaster. Here’s
a rundown of tax-related things that can help your client after a disaster:
• Receive more time to file and pay. If your client is
located in a disaster area, he may have extra time to file returns
and pay taxes. The IRS’s Twitter accounts
and disaster assistance
page provide disaster updates and links to resources or contact the IRS’s
disaster line at 866-532-5227.
• Qualify for a casualty loss tax deduction. If your client has
damaged or lost property due to a federally declared disaster, he may
qualify to claim a casualty loss deduction. He can claim this deduction on
his current or prior-year tax return, which may result in a larger refund.
• File for a disaster loan or grant. The Small Business Administration
offers financial help to business owners, homeowners and renters. This help
is for those in a federally declared disaster area. To qualify your client
must have filed all required tax returns.
• Request a tax return transcript. Clients affected by a disaster can
get copies or transcripts
of past tax returns for free by submitting either Form 4506, Request for
Copy of Tax Return or Form 4506-T, Request
for Transcript of Tax Return.
• Submit a change of address. If your client temporarily relocates
after a disaster, he should notify the IRS of the new address by
submitting Form 8822, Change of
For more information and tips, visit disasterassistance.gov.
3. Help Your Clients Understand IRS Notices
Did your client
receive a letter or notice from the IRS? The Understanding Your IRS/Notices
web page on IRS.gov explains in detail what certain IRS
notices mean and how to respond. Key in the notice or letter number in the
“Notices and Letters” search box to obtain a clear explanation of the
notice or letter and obtain answers to common questions.
4. Technical Guidance
Notice 2019-52 expands
the emergency housing and compliance monitoring relief provided in Rev.
Proc. 2014-49, 2014-37 I.R.B. 535, and Rev. Proc. 2014-50, 2014-37 I.R.B.
540, in response to the devastation caused by the 2018 California Wildfires
to Butte, Los Angeles, and Ventura counties in the State of California.
Revenue Ruling 2019- 23
provides various prescribed rates for federal income tax purposes including
the applicable federal interest rates, the adjusted applicable federal
interest rates, the adjusted federal long-term rate, the adjusted federal
long-term tax-exempt rate.