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IRS proposed regulation identifies certain micro-captive transactions as listed transactions and certain other micro-captive transactions as transactions of interest. Notice 2023-34, which provides that convertible virtual currency is treated as property for federal tax
USDT proposed regulations identifying certain micro captive transactions as listed transactions or transactions of interest for purposes of disclosure rules for taxpayers and material advisors. Proposed regulations in response to taxpayer victory in CIC Services LLC v. IRS
The IRS has issued proposed regulations that would abolish certain tax shelters. The agency's proposed rulemaking would classify certain ...
Tenth Circuit U.S. Court of Appeals affirmed a Tax Court decision, a micro-captive insurance company did not qualify for the exemption from income tax as a small insurance company under I.R.C.§501c15 as it did not have all four parts of framework for evaluating Insurance
In CIC Services, LLC v. IRS, the U.S. District Court for the Eastern District of Tennessee invalidated Notice 2016-66 and ordered the IRS to return disclosure documents obtained from taxpayers and material advisors who participated in micro-captive insurance arrangements.