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By: Derek B. Wheeler, Esq. It has now been more than a decade since the Patient Protection and Affordable Care Act (ACA) was signed into law by President Obama. Among the many requirements the law placed on taxpayers was requiring many businesses to offer minimum essential coverage to its employees. While much has been made of the substantive requirements of
By: Heather L. Marello, Esq. In a recent press release, IRS is again urging participants in abusive microcaptive insurance arrangements to cease participation in such transactions. This message comes after the Service’s recent win in the U.S. Tax Court in Caylor Land & Dev. v. Commissioner, T.C. Memo 2021-30 (2021). This win marks the fourth major victory in this area,
By: Randall P. Andreozzi, Esq. In 2016 the IRS issued Notice 2016-66, which identifies certain micro captive insurance transactions as potentially abusive. The Notice generally describes the abusive arrangement as one where owners of closely-held entities engage in a captive insurance arrangement that purports to ensure against certain risks associated with the business. The business pays “premiums” to the captive