January 27, 2020

January 27, 2020

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IRS Identifies Certain 831(b) Captives As “Transactions Of Interest”

In Notice 2016-66, the Treasury Department and the Internal Revenue Service (IRS) identified a particular § 831(b) “micro-captive” transaction as a “transaction of interest” for purposes of § 1.6011-4(b)(6) of the Regulations and §§ 6111 and 6112 of the Internal Revenue Code. The notice also alerts persons involved in such transactions to certain responsibilities and penalties that may arise from their involvement with these transactions.

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About this Author

Elizabeth Erickson McDermott Will Emery Law Firm Tax Attorney

Elizabeth Erickson is a partner in the law firm of McDermott Will & Emery LLP and is based in the Firm's Washington, D.C., office.  She is a member of the U.S. & International Tax Practice Group, and focuses her practice on tax controversies, including tax litigation. She has extensive experience in resolving domestic and international tax matters at all stages of dispute, including Internal Revenue Service examinations, administrative appeals, and litigation in the US Tax Court and district courts. She has advocated for clients before the Internal Revenue Service...

Kristen E. Hazel, Tax Attorney, McDermott Will Emery law firm

Kristen E. Hazel is a partner in the law firm of McDermott Will & Emery LLP and is based in the Firm’s Chicago office.  Kristen focuses her practice on U.S. and international aspects of federal tax matters including international acquisitions and joint ventures, captive insurance companies, and structuring and implementing partnership and limited liability company transactions.