IRS Memorandum 20211601F-20211606F: Variants of Micro-Captive Insurance Transactions Same As Specific Transaction

In each of six IRS Memoranda cases, the IRS stated that variant of the micro-captive insurance transactions promoted by an entity were the same as, or substantially similar to, the transaction of interest in Notice 2016-66 , I.R.B. 2016-47, 745. The micro-captive transactions involved captives formed by business owners to purportedly insure risks of their business entities. The IRS outlined five factors in section 2.01 of Notice 2016-66 and concluded the aforementioned.

To see the Memorandums:

Posted by Jessica Ji, Associate Editor, Wealth Strategies Journal.

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