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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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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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