IRS Issues Micro-Captive FAAs on Reporting and Penalties

May 5, 2021

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. Read More

IRS Creates Office To Focus on Abusive Micro-Captive Transactions

April 22, 2021

The US Internal Revenue Service (IRS) has created an Office of Promoter Investigations (OPI) to coordinate the agency's focus on abusive tax avoidance transactions, including abusive micro-captive insurance arrangements. The new office expands on the efforts of the IRS’ promoter investigations coordinator that began in the summer of 2020. Read More

SIIA Calls on IRS To Recognize Appropriate Captive Structures

April 20, 2021

The Self-Insurance Institute of America (SIIA) has responded to a recent statement by the Internal Revenue Service (IRS) on abusive micro-captive arrangements by calling on the IRS to move towards recognizing appropriate captive insurance structures and providing guidance. Read More

Washington State Lawmakers Give Final Approval to Captive Taxes, Fees

April 14, 2021

Legislation given final approval last week by Washington State lawmakers will set new requirements for captive insurance companies licensed in other domiciles but doing business in Washington. The legislation creates new fee and premium tax requirements for captives insuring Washington-based risks. Read More

IRS Warns Participants To Exit Abusive Micro-Captive Arrangements

April 13, 2021

The Internal Revenue Service (IRS) is urging participants in abusive micro-captive arrangements to exit those arrangements as soon as possible. The IRS said it has increased examinations of micro-captive arrangements and noted that it recently won another US Tax Court micro-captive case. Read More