On Friday, April 11, 2025, the Internal Revenue Service issued Notice 2025-24 (the “Notice”), which waives applicable penalties under the Internal Revenue Code to participants in, and material advisors to, reportable...more
4/15/2025
/ Captive Insurance Company ,
Disclosure Requirements ,
Filing Deadlines ,
Insurance Industry ,
Internal Revenue Code (IRC) ,
IRS ,
Penalties ,
Reporting Requirements ,
Risk Management ,
Tax Penalties ,
Tax Returns
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”) that named some...more
2/20/2025
/ Captive Insurance Company ,
Final Rules ,
Financial Services Industry ,
Income Taxes ,
Insurance Industry ,
Internal Revenue Code (IRC) ,
IRS ,
Reporting Requirements ,
Tax Returns ,
Treasury Regulations ,
U.S. Treasury
On Tax Day, May 17, 2021, in a unanimous opinion authored by Justice Kagan, the United States Supreme Court held that the Anti-Injunction Act ("AIA") does not bar a pre-enforcement challenge to the legality of an IRS-imposed...more