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January 24, 2019

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Settlement offers for micro-captive insurance schemes; letters to be mailed to groups under audit

September 20, 2019

 

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.