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
Continue Reading IRS Proposed Regulations Identify Micro-Captive Transactions as Listed Transactions – Responding to CIC Services Decision
On May 13, 2022, in Reserve Mechanical Corporation v. Commissioner,[1] the U.S. Court of Appeals for the Tenth Circuit affirmed a Tax Court decision that a micro-captive insurance
Continue Reading Another Micro-Captive-Case Loss: 10th Circuit Affirms Tax Court Ruling in Reserve Medical Corp. v. Commissioner
On April 19, 2021, the IRS announced the establishment of a new Office of Promoter Investigations (OPI). The creation of OPI demonstrates the IRS’s commitment to pursuing promoters and combating
Continue Reading IRS Establishes Office of Promoter Investigations with Emphasis on Conservation Easements and Micro-captive Insurance Arrangements
On April 9, 2021, the IRS urged taxpayers who engage in micro-captive insurance arrangements to exit these transactions. This announcement follows an IRS victory in the U.S. Tax Court, which
Continue Reading IRS Wins Again on Micro-Captive Arrangements, Urges Taxpayers to Exit Transactions
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
Continue Reading Second Round of Micro-Captive Insurance Settlements Provides Stricter Terms
Emboldened by significant victories in three Tax Court cases involving micro-captive insurance companies, on Jan. 31, 2020, the IRS announced that it is establishing 12 new examination teams to assist
Continue Reading IRS to Increase Enforcement Against Abusive Micro-Captive Insurance Transactions