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On April 10, 2023, the U.S. Treasury Department issued proposed regulations identifying certain micro-captive transactions as listed transactions or transactions of interest for purposes of the disclosure rules for taxpayers and material advisors. The proposed regulations are in response to a taxpayer victory in CIC Services, LLC v. IRS, in which the U.S. District Court for the Eastern District of Tennessee invalidated Notice 2016-66 for failing to comply with the Administrative Procedure Act. 

Continue reading the full GT Alert.