Captivating Thinking

(The below is informational only and does not constitute advice. Consult your independent tax advisor for specific recommendations or advice regarding your captive insurance structure.)

Over the last week the IRS appears to have sent a standard form letter to many (perhaps all) participants in captive insurance transactions covered by IRS Notice 2016-66. This does NOT appear to be a letter targeted at only specific taxpayers but rather something widely distributed among all captives that complied with Notice 2016-66. Continue Reading

Sometimes praise comes from the most unlikely sources.  With the economic onslaught caused by COVID-19, even a New York Times columnist is suggesting what we have always said – that small captives are a powerful risk management and survival vehicle for small and middle-market companies that can actually save businesses and save peoples’ jobs. Continue Reading

Over the past few months, we have been reporting on CIC Services’ lawsuit against the IRS and its unlawful Notice 2016-66.  In a split decision, the U.S. Sixth Circuit Court of Appeals denied granting an injunction against, IRS Notice 2016-66, but the dissenting opinion was powerful and compelling.  CIC Services has appealed the case to the U.S. Supreme Court and has picked up broad support in its case against the IRS and administrative state abuse of power.   Continue Reading