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

IRS Looks To Hire 200 Attorneys To Focus on Abusive Tax Schemes

January 25, 2022

The US Internal Revenue Service’s (IRS) office of chief counsel plans to hire up to 200 additional attorneys to focus on abusive tax schemes, including abusive micro-captive arrangements. The IRS said the attorneys will help it manage the increasing caseload in its multiyear effort to stamp out abusive tax schemes. Read More

Avoiding Potential Pitfalls Is Key to Long-Term Captive Success

December 13, 2021

Captive insurance can be a powerful risk management and risk financing tool, but those considering forming a captive must avoid potential pitfalls. A recent report from Ernst & Young LLP outlines five potential pitfalls prospective captive owners should be aware of to ensure long-term captive success. Read More