IRS Stirring the Pot Again with Micro-Captives: Settlements Announced

Current Events, Estate and Gift Tax, Income Tax, Tax Controversy

On September 16, 2019, the Internal Revenue Service (“IRS“) announced that it would be mailing settlement offers for certain taxpayers under audit who participated in “abusive” micro-captive insurance transactions. The micro-captive transactions were listed as a transaction of interest by the IRS back in 2016. Section 2 of Notice 2016-66 described the transaction itself as…
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