Taxation

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. Read More

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. Read More

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. Read More

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

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