On Friday, April 21, a District Court judge denied a taxpayer’s request Summary Judgement for a preliminary injunction to prohibit the IRS from enforcing the disclosure requirements set forth in Notice 2016-66. The Court’s ruling comes on the heels of the May 1st disclosure deadline the IRS has imposed on IRC § 831(b) captive insurance companies, their insureds, owners of the insureds, and material advisors to the transactions.
On November 1, 2016, the IRS issued the Notice 2016-66, which makes most IRC § 831(b) captive insurance arrangements, “transactions of interest,” which requires those involved to file yearly detailed disclosure statements with the IRS. The original due date for these disclosures was January 30, 2017. However, Notice 2017-08 pushed this deadline to May 1, 2017.
Notice 2016-66 generally requires captive insurance companies, their insureds, and owners of the insureds, to file Forms 8886 pertaining to the captive insurance arrangement if the […]