The Internal Revenue Service (IRS) has granted a 90-day extension the deadline for 831(b) captives that need to comply with the Notice 2016-66.
The IRS revealed, in Notice 2017-08 on 29 December 2016, that the new deadline for compliance is 1 May 2017.
Notice 2016-66 requires reporting by any taxpayer involved in micro captive transactions over a number of past years to which the open statute of limitations applies.
Abusive micro-captive transactions previously appeared on the IRS’s ‘Dirty Dozen’ list in 2015.
The Self-Insurance Institute of America (SIIA) has commented that, while it applauds the necessary deadline extension, there is a “continued belief that the requirements under the notice are duplicative and unnecessary at a time when the PATH Act provisions have not yet fully taken effect”.
SIIA suggested it will continue to lead advocacy activities aimed at reviewing and further modifying the notice.
