Court invalidates IRS notice 2016-66 on Micro-Captive Transactions, the second time an IRS notice was vacated this month by Lexology.
Greenberg Traurig LLP reports for Lexology on the U.S. District Court for the Eastern District of Tennessee invalidating Notice 2016-66 for failing to comply with the Administrative Procedure Act (APA) in CIC Services, LLC v. IRS. They highlight how CIC Services asserts that the IRS must comply with the APA in identifying reportable transactions at least in the Sixth Circuit.