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

By and on November 11, 2016

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.

Kristen E. Hazel
Kristen E. Hazel has extensive experience representing clients in US and international aspects of federal tax matters, including international acquisitions and divestitures, international joint ventures, and capital plan design and implementation. Her work includes both inbound and outbound transactions. Kristen is the co-chair of the Firm's Captive Insurance Affinity Group. She regularly counsels clients with respect to the tax aspects of organizing, operating and defending captive insurance companies. Read Kristen Hazel's full bio.


McDermott Will & Emery



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