Tag: Settlement Offer

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

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