The mailing of a time-limited settlement offer for certain taxpayers under audit who participated in abusive micro-captive insurance transactions.
Those of you eligible for this offer will be notified by letter with the applicable terms. Those who do not receive such a letter are not eligible for this resolution.
Abusive micro-captives have been a concern for several years. The transactions have appeared on the IRS "Dirty Dozen" list of tax scams since 2014. In 2016, the Department of Treasury and IRS issued Notice 2016-66 (PDF), which identified certain micro-captive transactions as having the potential for tax avoidance and evasion.