IRS Memorandum 20211701F: Field Attorney Advice on Micro-Captive Transactions Issued (April 30, 2021)

In IRS Memorandum 20211701F (April 30, 2021), the IRS Chief Counsel ruled that the variant of the micro-captive insurance transactions promoted by an entity were the same as, or substantially similar to, the transaction of interest described in Notice 2016-66 , I.R.B. 2016-47, 745. The Chief Counsel analyzed the taxpayer’s situation by applying the five factors mentioned under section 2.01 of Notice 2016-66.

To see IRS Memorandum 20211701F (April 30, 2021) click here.

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

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