Taxation

IRS Adds Abusive Micro-Captive Arrangements to 2022 Dirty Dozen List

June 17, 2022

The US Internal Revenue Service (IRS) has added abusive micro-captive arrangements to the final version of its 2022 "Dirty Dozen" list of potentially abusive tax schemes. Earlier in June, the IRS had included foreign captive insurance arrangements on the first installment of entrants on this year's Dirty Dozen list. Read More


IRS Includes Foreign Captive Insurance on 2022 "Dirty Dozen" List

June 7, 2022

Foreign captive insurance transactions found a place on the Internal Revenue Service's 2022 "Dirty Dozen" list of potentially abusive tax arrangements. The IRS said the four arrangements on the first group on its 2022 list "will likely attract additional agency compliance efforts in the future." Read More


US GAO Recommends Improvements in IRS Micro-Captive Audit Process

April 28, 2022

The US Government Accountability Office (GAO) has recommended that the Internal Revenue Service (IRS) clarify guidance on offshore micro-captive insurance audits and establish a formal review system for investigations. A GAO statement detailed the findings of its study into how the IRS conducts its enforcement of offshore insurance compliance issues. Read More


Judgment in Micro-Captive Reporting Case Vacates IRS Notice 2016-66

March 24, 2022

A federal judge has granted a summary judgment motion filed by CIC Services in its case against the Internal Revenue Service (IRS), vacating IRS Notice 2016-66. The judge held that the IRS violated the federal Administrative Procedures Act in adopting the notice, and was arbitrary and capricious in doing so. Read More


Captive Insurance Groups' Brief Supports Delaware Appeal in IRS Case

March 22, 2022

A coalition of 10 captive insurance associations filed an amicus brief this month in support of an appeal brought by the Delaware Department of Insurance in the case of United States of America v. State of Delaware Department of Insurance. Read More