Certain micro-captive transactions are back to being reportable. On January 14, 2025, the Treasury Department and the Internal Revenue Service (“IRS”) published final regulations (the “Regulations”) ...

Following the 11th Circuit's ruling in Green Rock LLC v. IRS this past summer, the IRS has decided to cease its defense of post-American Jobs Creation Act (AJCA) reportable transaction notices. In an ...

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The Internal Revenue Service issued a notice Friday giving some breathing room to participants and advisors involved with micro-captive insurance companies. However, the micro-captive insurance ...

The United States Treasury Department building in Washington, D.C. Eight years ago, in December of 2016, the IRS issued the ill-fated first set of reporting requirements for 831(b) microcaptive ...

The United States is an attractive place for entrepreneurs and investors from around the globe for various reasons. It provides access to a huge consumer base, strong legal protections, and a thriving ...

On Oct. 7, the IRS finalized regulations identifying certain syndicated conservation easement (SCE) transactions as listed transactions, a type of transaction with additional reporting requirements.

The IRS issued final regulations Monday (T.D. 10007) that identify certain abusive syndicated conservation easement transactions and substantially similar ones as reportable listed transactions. The ...