On Oct. 22, 2020, the IRS announced it is offering a second time-limited settlement initiative to certain taxpayers who participated in abusive micro-captive insurance transactions and who currently are under audit. This second round of settlement offers, to be mailed in the coming days, has stricter settlement terms than the IRS’s first time-limited initiative. This increase in enforcement is occurring after the IRS deployed 12 newly formed micro-captive examination teams to increase the examination of micro-captive insurance transactions.

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