Captive Notes from the Trenches

Captive Notes from the Trenches
By Michael E. Lloyd, Esq.

IRS Issues Proposed Captive Reportable Transaction Regulations. On April 11, 2023, the IRS published
Proposed Regulations under §1.6011-10 and §1.6011-11. These Regulations identify certain microcaptive
arrangements as listed transactions, and/or transactions of interest. When finalized, these regulations will confirm the requirement to file Forms 8886 with respect to participation in certain microcaptive
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