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
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.
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.
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.
Eastern District of Tennessee invalidated Notice 2016-66 for failing to comply with Administrative Procedure Act APA, granted broad injunctive relief IRS return to taxpayers and material advisors documents obtained improperly. Ruling implicates thousands of disclosures.