J.H. Briscoe

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Our Thoughts on 2016-66

This IRS Notice, effective November 1, 2016, identifies certain “micro-captive transactions” as “transactions of interest” because these types of transactions may have the potential for tax-avoidance or evasion. This notice recognizes that many micro-captive transactions are utilized for risk management purposes and do not involve tax avoidance. However, the IRS has identified companies taking advantage of IRC §831(b) (“Investment Income Reinsurance Companies”) as a transaction of interest and has mandated that all the participants (dealership, dealership shareholders, agents and underwriters) involved in such reinsurance transactions must disclose the transaction details to the IRS. A p

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