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Rachel Partain, Charles Ruchelman, Mark Allison, and Christopher Rizek Discuss What's Next in Micro-Captive Transactions on AICPA Webinar

August 24, 2017
Speakers:Rachel L. Partain, Charles M. Ruchelman, Mark D. Allison, Christopher S. Rizek
Program:Micro-Captive Transactions: What's Next and How Can You Prepare
Event Sponsor:AICPA

For the past several years, the Internal Revenue Service ("IRS") has been focusing on small captive insurance companies. Currently, the IRS is committing significant resources to examining insureds, captive insurance companies, and captive managers. There are also numerous cases docketed in the U.S. Tax Court. Furthermore, on November 1, 2016, the IRS issued Notice 2016-66 identifying certain transactions relating to small captive insurance companies as a "transaction of interest." The new designation triggers disclosure requirements with significant penalties for non-compliance. Finally, the IRS Large Business & International Division has created a coordinated effort to examine captive insurance issues in its recently-announced “campaign” program.

Please join Rachel L. Partain, Charles M. Ruchelman, Christopher S. Rizek, and Mark D. Allison for this 1-hour webinar designed to educate CPAs on how to navigate the IRS examinations and the new reportable transaction disclosure requirements.

Learning outcomes include:

  • Understanding the tax implications of establishing a small captive insurance company under section 831(b) of the Internal Revenue Code.

  • Understanding of the IRS’s concerns with small captive insurance companies.

  • Understanding the tools used by the IRS to examine insureds, captives, and captive managers.

  • Understanding of the IRS disclosure regime for transactions of interest (TOI) under Internal Revenue Code and Treasury Regulations for transaction participants and advisors.

  • Understanding of the penalties for failure to disclose a TOI under Internal Revenue Code and Treasury Regulations for transaction participants and advisors.