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.
- IRS Memorandum 20211601F (February 5, 2021) click here.
- IRS Memorandum 20211602F (February 5, 2021) click here.
- IRS Memorandum 20211603F (February 5, 2021) click here.
- IRS Memorandum 20211604F (February 5, 2021) click here.
- IRS Memorandum 20211605F (February 11, 2021) click here.
- IRS Memorandum 20211606F (February 9, 2021) click here.
Posted by Jessica Ji, Associate Editor, Wealth Strategies Journal.
