An Atlanta Tax Attorney Who Understands Captive Insurance Litigation Cases
Former IRS Chief Counsel attorney Cal Bomar and the lawyers at our law firm represent clients who are undergoing an audit relating to a captive insurance company, and who have cases in U.S. Tax Court or U.S. District Court relating to captive insurance companies.
Bomar Law Firm’s principal office is located in Atlanta, Georgia. However, the firm assists clients in tax matters throughout the United States.
Why Representation Is Necessary
In Notice 2016-66, the IRS stated that some taxpayers may use captive insurance companies that make elections under Section 831(b) “for risk management purposes that do not involve tax avoidance.”
The IRS has sought in the past to argue that some of these entities do not provide real insurance, and that the transactions have no “economic substance.” Therefore, they asserted that the IRS should be able to assess tax, interest and severe penalties against the captive insurance company and its insured. They also have sought penalties against promoters that set up the captives.
For a detailed analysis of your captive insurance audit or case related to a captive insurance company, contact Bomar Law Firm at (404) 841-6561. Cal Bomar represents taxpayers in captive insurance cases as well as other tax controversies. Our Atlanta tax attorneys handle cases involving captive insurance company litigation and syndicated conservation easement IRS audits, guiding clients through IRS tax disputes.