Micro-Captives, Foreign Captive Insurance on IRS 2023 Dirty Dozen List

April 6, 2023

The Internal Revenue Service (IRS) has released its 2023 Dirty Dozen list, and once again, micro-captives and Puerto Rican and foreign captive insurance are included on the list. The IRS said the list is meant to alert taxpayers, businesses, and tax professionals of potentially abusive tax arrangements and scams. Read More

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