The Internal Revenue Service and the Treasury Department proposed regulations to identify micro-captive transactions as abusive tax transactions after the Supreme Court ruled against the IRS in a case ...
Certain micro-captive transactions are back to being reportable. On January 14, 2025, the Treasury Department and the Internal Revenue Service (“IRS”) published final regulations (the “Regulations”) ...
A federal court in Texas vacated the regulation that defines micro-captive insurance companies as a listed transaction. [1] That case is currently being appealed. That is not to say that ...
A Texas federal judge ruled against the Internal Revenue Service in a case involving its classification of micro-captive insurance as a "listed transaction," but also ruled in favor of the IRS ...
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