Captive Reporting – WE CAN HELP!

Welcome to our web site for individuals and business entities who must comply with new IRS Notice requirements relating to 831(b) captive insurance companies.

Williams Coulson is uniquely positioned to help taxpayers prepare and file Forms 8886. Williams Coulson has previously prepared more than 3,000 Forms 8886 under similar time constraints during three separate reportable transaction periods. Williams Coulson has represented more than 500 clients in IRS Exam, Appeals and Tax Court with respect to participation in those reportable transaction, including representation of taxpayers who failed to have Forms 8886 prepared.

Currently, Williams Coulson is representing taxpayers in IRS Exam, Appeals and Tax Court with respect to participation in captive insurance companies and understands the IRS perceived abuses.


1. What is IRS Notice 2016-66?
In general, a Notice is a type of guidance to taxpayers published by the IRS. It is not a law (in the tax world referred to as a Section of the Internal Revenue Code) nor is it a Regulation that relates to a Code Section. Instead, IRS Notices generally provide information on a tax subject or sometimes identify new requirements that apply to taxpayers. In this case, Notice 2016-66 identifies certain captive insurance programs as “transactions of interest” and creates a filing requirement that applies to all participants in the identified captive programs.

2. What is a “Transaction of Interest?” 
A “transaction of interest” that the IRS and Treasury Department believe has a potential for tax avoidance or evasion but for which there is not enough information to determine if the transaction should be identified as a tax avoidance transaction.

3. Does this mean that all captives are bad? 
No. The IRS recognizes that Read More