More about the IRS TAMs

Two Portfolio program clients were examined by the IRS, during which time they were subjected to a multi-pronged, two year review by the Service. At the conclusion of the examination, the Service published two Taxpayer Advice Memoranda that showed their reinsurance companies served a legitimate business purpose in a way that was proper and correct.
While the Internal Revenue Code section 6110(k)(3) states that the TAMs may not be used or cited as precedent, the fact remains that the Portfolio program has undergone extensive review by the IRS and its two clients were found to be in compliance with Federal tax law. To Portfolio’s knowledge, no other similar program can boast the same success.

Close Popup