2016-66 Update: Ryan LLC Joins CIC Services as Plaintiff Against IRS
Despite an avalanche of comments from all corners of the captive insurance industry criticizing Notice 2016-66 as unnecessarily burdensome, an affront to Congress, abusive and even downright vindictive (given the Service’s inability to win against captives in U.S. Tax Court), the Internal Revenue Service (IRS) has not altered course. The IRS’s reluctance to reconsider Notice 2016-66 has lead Ryan, LLC to join