Captive Notes from the Trenches
By Michael E. Lloyd, Esq.
4/19/2023
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
transactions.
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