KPMG report: Federal district court vacates Notice 2016-66 (microcaptive insurance transactions) (March 23, 2022)

KPMG has made available for download their article, “Federal district court vacates Notice 2016-66 (microcaptive insurance transactions)”, which discusses the U.S. District Court for the Eastern District of Tennessee’s invalidation of Notice 2016-66. The abstract is as follows:

The U.S. District Court for the Eastern District of Tennessee this week held that Notice 2016-66 was invalid because the IRS did not comply with the notice-and-comment requirements set forth in the Administrative Procedure Act (APA) and because the IRS acted arbitrarily and capriciously in issuing the notice.

The federal district court vacated Notice 2016-66 and ordered the IRS to return all documents and information produced as a result of the notice.

The decision comes following a long procedural journey from the district court through appeals to the Sixth Circuit and the U.S. Supreme Court and back to the district court on remand.

The case is: CIC Services, LLC v. IRS, No. 3:17-cv-110 (E.D. Tenn. March 21, 2022). Read the district court’s decision [PDF 257 KB]

To see the full article, click: “Federal district court vacates Notice 2016-66 (microcaptive insurance transactions)”

Posted by Marin Larkin, Associate Editor, Wealth Strategies Journal.

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s