SECTION 1. PURPOSE

This notice provides relief from penalties under section 6707A(a) of the Internal

Revenue Code (Code) ¹ to participants in micro-captive reportable transactions that fail to file certain disclosure statements required under section 6011 and § 1.601110(h)(2) or § 1.6011-11(h)(2) by April 14, 2025. This relief applies only if such participants file the required disclosure statement with the Office of Tax Shelter Analysis (OTSA) by July 31, 2025. In addition, this notice provides relief from penalties under section 6707(a) for material advisors to certain micro-captive reportable transactions that are required under section 6111 and § 1.6011‑10(h)(3) or § 1.6011-11(h)(3) to file a disclosure statement with OTSA by April 30, 2025, if such material advisors file the disclosure statement with OTSA by July 31, 2025. The relevant penalties will be waived as described in section 3 of this notice.