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Micro-Captive Reportable Transaction Deadline Effectively Extended

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

CIC Services, LLC v. Internal Revenue Service: Captive Insurance Wins a Battle, but the War Continues

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

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