Notice 2016-66 alerted taxpayers and
Internal Revenue Bulletin 2023-17 · 2026-10-03 edition · updated 2026-10-04 · United States
their representatives pursuant to §1.60114(b)(6) and for purposes of §1.6011-4(b) (6) and sections 6111 and 6112, that the Treasury Department and the IRS identified as transactions of interest certain micro-captive transactions in which a taxpayer attempts to reduce the aggregate taxable income of the taxpayer, related persons, or both, using contracts that the parties treat as insurance contracts and a related company that the parties treat as an insurance company. Notice 2016-66 also alerted persons involved with the identified transactions that certain responsibilities may arise from their involvement.
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