A federal judge has granted a preliminary injunction barring the US Internal Revenue Service (IRS) from enforcing its micro-captive reporting requirement on CIC Services. The September 21, 2021, ruling comes after the US Supreme Court earlier this year overturned a previous federal district court ruling rejecting CIC's injunction motion.
Although it should come as no surprise, in CCM 202134017, the Internal Revenue Service (IRS) has made clear its position regarding micro-captives formed in a jurisdiction outside the United States.
The Office of the Insurance Commissioner for Washington State has issued draft regulations to implement legislation state lawmakers passed in April that sets new requirements for captive insurance companies licensed in other domiciles but doing business in the state of Washington. Washington State insurance regulators described the new law as a fair compromise.
The government of Bermuda has joined the Organization for Economic Cooperation and Development's (OECD) "Inclusive Framework" for international taxation. A statement said Bermuda officials look forward to supporting the OECD's ongoing technical discussions ahead of the G20 foreign ministers' meeting in October 2021.
After a year's absence, abusive micro-captive arrangements have returned to the US Internal Revenue Service's (IRS) annual "Dirty Dozen" list of "tax scams." The IRS had left micro-captives off its 2020 Dirty Dozen list, the first time in 5 years they weren't included.
In a unanimous ruling, the US Supreme Court held that captive manager CIC Services' challenge of an Internal Revenue Service (IRS) micro-captive reporting requirement is not prohibited by federal law. In its ruling, the high court overturned a federal district court ruling and remanded the case to the lower court.
The Internal Revenue Service (IRS) recently issued six field attorney advices, referred to as "FAAs," considering whether certain promoted micro-captive transactions under audit are substantially the same as the transactions of interest described in Notice 2016–66, and concluding they were.