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IRS Proposed Regulations Identify Micro-Captive Transactions as Listed Transactions – Responding to CIC Services Decision

By Barbara T. Kaplan & Courtney A. Hopley on April 12, 2023

Posted in Administrative Procedures Act, Featured, Internal Revenue Code, IRS, Tax

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…

6th Circuit Rules IRS Must Follow Administrative Procedures Act in ‘Listing’ Transactions, Raising Questions on Extent of Case’s Application

By Courtney A. Hopley, Barbara T. Kaplan & Scott E. Fink on March 4, 2022

Posted in Administrative Procedures Act, Featured, GT Alert, IRS, Sixth Circuit, Tax

On March 3, 2022, the U.S. Court of Appeals for the Sixth Circuit ruled in Mann Construction, Inc. v. U.S.¹ the IRS must follow the Administrative Procedures Act (APA)…
Continue Reading 6th Circuit Rules IRS Must Follow Administrative Procedures Act in ‘Listing’ Transactions, Raising Questions on Extent of Case’s Application

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Administrative Procedures Act

IRS Proposed Regulations Identify Micro-Captive Transactions as Listed Transactions – Responding to CIC Services Decision

6th Circuit Rules IRS Must Follow Administrative Procedures Act in ‘Listing’ Transactions, Raising Questions on Extent of Case’s Application

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