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April 10, 2023

IRS proposed regulations identify some micro-captive transactions that will qualify as listed transactions or transactions of interest

The IRS has issued proposed regulations (REG-109309-22) identifying transactions that are the same as, or substantially similar to, certain (1) micro-captive transactions as listed transactions and (2) other micro-captive transactions as transactions of interest. Material advisors and certain participants in these listed transactions and transactions of interest must file disclosures with the IRS or face penalties. A public hearing by teleconference is scheduled for July 19, 2023; comments on the regulations may be sent to the IRS through June 10, 2023.

Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor