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United States’ decision in CIC Servs., LLC v. IRS, which allowed a pre-enforcement challenge to the IRS’s reportable transaction regime. 6th circuit rejected the IRS’s request to limit vacatur of the Notice to CIC, explaining that vacating the Notice is appropriate
LLC v. IRS,1 the U.S. District Court invalidated Notice 2016-66 for failing to comply with the Administrative Procedure Act. Notice 2016-66 prescribed disclosure requirements for taxpayers and material advisors involved in certain micro-captive transactions.
The Sixth Circuit has now reversed the district court in Mann Construction, holding that the IRS’s process for issuing Notice 2007-83—which designates certain employee-benefit plans featuring cash-value life insurance policies as listed transactions—violated the APA.