August 12, 2022

Volume XII, Number 224

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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.

© 2022 McDermott Will & EmeryNational Law Review, Volume VI, Number 316
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About this Author

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

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. 

312-984-3696
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