Thursday, December 17, 2020 On December 1, 2020, the United States Supreme Court heard oral arguments in CIC Servs. LLC v. Internal Revenue Service, a case challenging the Internal Revenue Service’s (IRS) reporting requirements around certain transactions involving captive insurance companies that elect to be taxed under § 831(b) of the Internal Revenue Code (referred to as “micro-captives”). Background The IRS has established requirements for certain taxpayers, as well as their advisors, to maintain specific records and submit reports to the IRS relating to any "reportable transactions," i.e., a transaction the IRS believes has the potential for tax avoidance or evasion. Reportable transactions are different from “listed transactions,” which are transactions the IRS deems to be unlawful tax avoidance mechanisms.