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For those wishing to protect their captive, we’ll get you compliant. And for those facing an audit, we’ll be your defense. Businesses have been creating captive insurance companies (CICs) for more than 100 years in order to manage risk while taking advantage of the tax benefits offered by the insurance arrangement.

However, the IRS has started to evaluate possible abuses surrounding CICs, and has begun examinations in the area. For those businesses who are unprepared when facing examination, there can be consequences.

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alliantNational leverages its years of experience with protecting taxpayers to help its clients navigate the complex world of captive insurance compliance, with its team of former high-ranking IRS executives, key congressional personnel and experienced litigators ensuring that each client has the strongest defense possible in the event of an audit.

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If you or your client wants to protect their CIC, the time to become compliant is now. alliantNational’s team of experts helps with: Risk Pool and UTP Review FIN 48 Analyses

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ERC Controversy Services from alliantNational

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We’ll Be Your Defense

As stated in IR-2024-78, the IRS is ramping up its enforcement on inaccurate or false ERC claims, leaving many businesses that worked with ERC promoters in jeopardy.
If you have concerns about your ERC claim, the time to act is now, as the IRS plans to send tens of thousands more disallowance letters and audit notices in the coming weeks.
Your claim could be considered fraudulent if your business:
  • Claimed all available quarters
  • Claimed max value of credit (26k per employee)
  • Provided no documentation of qualifying government mandates
  • Provided no numerical calculation of more than nominal impact to business
  • Failed to demonstrate a nexus between mandates and more than nominal impact

What We Do

Our ERC Controversy Services are tailored to help businesses that may have erroneously claimed the ERC credit.
  • ERC Refund Recovery
  • ERC Remediation & Withdraw
  • ERC Audit Defense
  • Form 6612 Response
  • Documentation of More than Nominal Impact
Many businesses are unaware that their claims are defective due to a horde of unscrupulous providers that misled innocent business owners into falsely overclaiming.
If you have doubts in the validity of your claim, or you are already in audit, our team can help you get the best resolution for your business.

Members of the alliantNational Team:

Our team, composed of world class experts in tax and law, includes five Commissioners and Deputy Commissioners as well as other officials, who understand how the IRS approaches fraud and their plans to combat faulty claims.

Darren Guillot

Former IRS Deputy Commissioner
of the SB/SE Division

Eric Hylton

Former IRS Commissioner of the SB/SE Division

Kathy Petronchak

Former IRS Commissioner of the SB/SE Division

Steven Miller

Former IRS Commissioner; alliantgroup Vice Chairman

Mark Everson

Former IRS Commissioner; alliantgroup Vice Chairman

alliantNational ERC Controversy Services

Refund Recovery

Wondering where your refund is? Through our decades of experience, we understand the best channels through which to collaborate with the IRS on your claim. Our team will reach out to the Service on your behalf, and work with you to see your claim through to the end.

Remediation Services

Thinking you need to withdraw your claim? Our team, armed with insights from our 9 former IRS executives, understands how to work with the Service to resolve the situation amicably. If you have questions about the withdrawal program, we can help you navigate the process and put you in the best position to avoid possible penalties.

Audit Defense

Already in audit, or concerned you are at risk? Our team can defend your ERC claim. We have decades of experience successfully defending businesses from IRS audits and understand how to follow the letter of the law regarding claims. We can also help resolve issues related to your former provider, including contracts, fees, etc.

Documentation of more than nominal impact

Did your previous ERC provider provide any form of documentation or substantiation that shows how it was tied directly to government mandates? Did you see a quantifiable (10%+) impact to the business? Are you able to demonstrate the nexus between the two?
If you are unaware of any of the above, or have zero documentation tied to your claim, our team can reconduct your study and help you truly evaluate how much benefit your entitled to. This way, you have the documentation you need to defend your claim.

Form 6612

Have you received a 6612 Letter? The IRS has begun sending thousands of 6612 Letters out to businesses who filed an ERC claim following the moratorium last September. Recipients have 30 days to respond or risk a disallowance of their claim. Our team can evaluate your ERC study and help you substantiate your existing claim, as well as highlight discrepancies caused by your previous provider.

alliantNational ERC Controversy Services

See for yourself how we’ve been able to put businesses just like yours at ease with their ERC claims:

Shady Payroll Provider

  • Payroll provider claimed ERC without taxpayer’s knowledge
  • Taxpayer received audit notice for $1.3MM claim
  • We rebuilt entire study and found qualification for all seven quarters
  • Original credit claim was preserved, but with substantiation

ERC Mill 4x Overclaim

  • Using only a questionnaire for substantiation, claimed $2.1MM for 7 quarters
  • No analysis of more than nominal impact conducted
  • We also found PPP and FFCRA were not taken into account
  • Actual credit amount was $512k for only 2 quarters

Our Mission

alliantNational assists CPAs and U.S. businesses alike in navigating difficult tax matters, offering both representation and support while working with IRS and state tax officials.
With insights from our 5 former IRS Commissioners and Deputy Commissioners, our team understands the intent of the Employee Retention Credit and what the Service is looking for to substantiate claims. We have assessed ERC eligibility for over 60,000 business, as well as assisted businesses who went with less reputable providers in rectifying their claims. With our team supporting yours, you can rest assured that you will receive what you are entitled to while following the letter of the law.
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Contact our team today with any tax controversy concern you’re facing. We fight every day to protect the interests of the taxpayer, and we look forward to putting you in the best tax situation possible.
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