💼New IRS Regulations on Micro-Captive Transactions Compliance
Micro-Captive Listed Transactions and Micro-Captive Transactions of Interest
Summary
This document contains final regulations that identify transactions that are the same as, or substantially similar to, certain micro-captive transactions as listed transactions, a type of reportable transaction, and certain other micro-captive transactions as transactions of interest, another type of reportable transaction. Material advisors and certain participants in these listed transactions and transactions of interest are required to file disclosures with the IRS and are subject to penalties for failure to disclose. The final regulations affect participants in these transactions as well as material advisors.
Agencies
- Treasury Department
- Internal Revenue Service
Business Impact
$$ - Med
The regulations impose compliance requirements for participants in specific micro-captive transactions, mandating disclosures that could lead to penalties for non-compliance. This affects business owners and executives who must adhere to the new reporting obligations as of January 14, 2025.