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Proposed IRS Regulations Identify Micro Captive Transactions

USDT proposed regulations identifying certain micro captive transactions as listed transactions or transactions of interest for purposes of disclosure rules for taxpayers and material advisors. Proposed regulations in response to taxpayer victory in CIC Services LLC v. IRS ....

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Tenth Circuit on Micro Captive Insurance Company And Tax Exemptions

Tenth Circuit U.S. Court of Appeals affirmed a Tax Court decision, a micro-captive insurance company did not qualify for the exemption from income tax as a small insurance company under I.R.C.§501c15 as it did not have all four parts of framework for evaluating Insurance ....

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CIC Services, LLC v. IRS - Motion for Reconsideration Granted

In CIC Services, LLC v. IRS, the U.S. District Court for the Eastern District of Tennessee invalidated Notice 2016-66 and ordered the IRS to return disclosure documents obtained from taxpayers and material advisors who participated in micro-captive insurance arrangements. ....

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The Saga Continues in CIC Services v. IRS: Government Moves to Prevent IRS from Returning Disclosure Documents Obtained from Nonparties Under Notice 2016-66 | Insights

On March 21, 2022, the U.S. District Court for the Eastern District of Tennessee invalidated Notice 2016-66 for failing to comply with the Administrative Procedure Act (APA) and granted broad injunctive relief requiring the IRS to return to taxpayers and material advisors the documents and information obtained improperly under the Notice. ....

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The Saga Continues in CIC Services v. IRS: Government Moves to Prevent IRS from Returning Disclosure Documents Obtained from Nonparties Under Notice 2016-66 | Insights

On March 21, 2022, the U.S. District Court for the Eastern District of Tennessee invalidated Notice 2016-66 for failing to comply with the Administrative Procedure Act (APA) and granted broad injunctive relief requiring the IRS to return to taxpayers and material advisors the documents and information obtained improperly under the Notice. ....

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