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.
Wealth Strategies Journal 