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District court strikes down microcaptive listed-transaction notice

Mar 25, 2022 | Captive Insurance, Insurance Industry

A federal district court, relying on the Sixth Circuit’s decision in Mann Construction, has vacated the IRS notice identifying microcaptive insurance arrangements as “listed” transactions and ordered the IRS to return all documents and information that taxpayers and...

IRS: we’ve stepped up audits of micro-captive insurance arrangements

Apr 14, 2021 | Captive Insurance, IRS information

In a News Release, IRS has said that it has stepped up its examinations of micro-captive insurance arrangements and has urged participants in abusive micro-captive insurance arrangements to exit those transactions as soon as possible. Background. A micro-captive...

IRS makes new stricter offer to settle micro-captive insurance audits

Oct 23, 2020 | Captive Insurance, IRS information

In a News Release, the IRS has announced a new, stricter limited-time settlement offer for certain taxpayers who participated in abusive micro-captive insurance transactions. Background. Broadly speaking, a micro-captive transaction is a transaction in which a...

IRS provides updated information regarding micro-captive insurance transactions

Oct 5, 2020 | Captive Insurance, IRS information

In a News Release, IRS has provided updated information on its enforcement efforts with respect to micro-captive insurance transactions. Background. Broadly speaking, a micro-captive insurance transaction is a transaction in which a taxpayer attempts to reduce the...

June 4 New Deadline for Taxpayer Response to IRS Micro-Captive Insurance Letter

May 7, 2020 | Captive Insurance, COVID-19 Information

In a statement, the IRS has automatically extended the due date of responses to IRS Letter 6336 from May 4, 2020 to June 4, 2020. Background. The IRS has concluded that certain micro-captive insurance company transactions had the potential for tax avoidance and...

IRS OFFERS SETTLEMENT FOR TAXPAYERS ENGAGED IN MICRO-CAPTIVE INSURANCE TRANSACTIONS

Sep 19, 2019 | Captive Insurance, IRS information

The IRS has announced that it is mailing a time-limited settlement offer to certain taxpayers under audit who participated in abusive micro-captive insurance transactions. Background. Broadly speaking, a micro-captive transaction is a transaction in which a taxpayer...
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