IRS Expands Enforcement Focus on Abusive Micro-Captive Insurance Schemes

In IR 2020-226, the Internal Revenue Service, on 10/1/2020, encouraged taxpayers to consult an independent tax advisor if they participated in a micro-captive insurance transaction. The IRS encourages any taxpayer who has continued to engage in an abusive micro-captive insurance transaction to not anticipate being able to settle its transaction with the IRS or Chief Counsel on terms more favorable than previously announced settlement offers and that any potential future settlement initiative that the IRS may consider will require additional concessions by the taxpayer. With this in mind, the IRS encourages taxpayers to consult an independent tax advisor if they participated in a micro-captive insurance transaction. These taxpayers should seriously consider exiting the transaction and not claiming deductions associated with abusive micro-captive insurance transactions, just like many other taxpayers...