The Counsel of the Internal Revenue Service (IRS) faced tough questions at the oral arguments in front of the Supreme Court Justices in its case against CIC Services over Notice 2016-66.
The new time-limited settlement offers will be sent out by the IRS in the coming days with terms that are “stricter” than the first time-limited initiative that started in September last year
The IRS' statement "is a combination of past talking points that are meant to scare business owners utilising captives into exiting their captive structures, regardless of whether they are doing the right thing or not”, says Ryan Work of SIIA
The IRS said taxpayers should not assume it will able to settle any transactions with the IRS or chief counsel on terms more favourable than the previously announced settlement offers
The IRS has urged the US Supreme Court to affirm the Sixth Circuit's rejection of CIC Services challenge to agency reporting requirements, stating that the lower court correctly found the suit is barred by the Anti-Injunction Act
Offshore micro captive insurance products were listed as a potential “abusive tax scheme” in a study by the US Government Accountability Office
A judge at the US District Court for the Middle District of Alabama has ruled in favour of Christopher Jarvis, former owner of Jade Risk, after he filed a lawsuit against Arsenal Insurance, a subsidiary of TaylorChandler, for breach of contract
Nearly two dozen national and state organisations in the US have filed a joint amicus brief before the US Supreme Court in the case of CIC Services LLC v. Internal Revenue Services
Insurance tax professionals discuss the current tax and regulatory landscape of the captive industry, including the OECD’s BEPS plan and IRS scrutiny of micro captives
Industry experts discuss why companies are choosing to redomesticate their captives and the opportunities it provides them
Phil Karter, Scot Kirkpatrick and Patrick McCann of Chamberlain Hrdlicka discuss the IRS’ letter, which raises more questions about captive audits in an already certain time
Ryan Work of SIIA discusses the IRS’ ‘ill-timed’ letter to captive insurance companies and the future of business risk as many US states started to institute stay at home orders
Sean King of CIC Services discusses the firm’s upcoming case against the IRS in the Supreme Court, what a win would mean for the industry, and the support they are receiving from the captive insurance industry throughout this legal process
Jeremy Colombik of MSI and NCCIA chair explains to Becky Butcher that Notice 2016-66 could be detrimental to not just North Carolina, but other domiciles that are home to smaller captives
The IRS has increased its scrutiny of captives, but those that follow the rules have nothing to worry about, as John Dies of alliantgroup tells Becky Butcher
As the sun sets on his tenure as CICA president, Dennis Harwick explains why this adolescent industry is wiser than its years
