July 14, 2021
A U.S. Supreme Court challenge to IRS microcaptive insurance transaction reporting requirements might not have proceeded if the transactions themselves were taxed instead of the reporting requirements being backed up with tax penalties, the Congressional Research Service said.
May 17, 2021
The U.S. Supreme Court Monday revived an advisory firm's challenge to IRS guidance requiring microcaptive insurance transactions to be disclosed on pain of penalties, saying it was not barred by the Anti-Injunction Act.
January 03, 2021
In 2021, courts will examine administrative law challenges to microcaptive and conservation easement tax regulations, what qualifies for a domestic manufacturing deduction and whether partnership disguised sale rules apply to an ownership transaction involving the Chicago Cubs baseball team. Here, Law360 looks at four federal tax cases to watch in the first half of the year.
October 09, 2020
The IRS' argument that a case challenging microcaptive insurance arrangement rules should be barred by a statute that bans litigation designed to curtail collecting or assessing taxes mischaracterizes the lawsuit, an insurance management company told the U.S. Supreme Court.
September 23, 2020
From CIC Services' challenge of the Internal Revenue Service's position on microcaptive insurance to a state-federal unclaimed property dispute to a state sovereignty matter, there is plenty for state tax experts to watch in the Supreme Court this fall. Here, Law360 looks at three cases for state tax mavens on the high court's docket.
September 16, 2020
The U.S. Supreme Court will hear a case challenging an Internal Revenue Service notice on microcaptive insurance transactions on Dec. 1, according to a calendar released Wednesday.
September 15, 2020
The U.S. Supreme Court should reject a microcaptive insurance company's challenge to certain IRS reporting requirements because it would restrain tax collection and make it easier to use abusive tax shelters, a group of former tax officials said Tuesday.
September 08, 2020
The Internal Revenue Service urged the U.S. Supreme Court Tuesday to affirm the Sixth Circuit's rejection of a microcaptive insurer's challenge to agency reporting requirements, saying the lower court correctly found the suit is barred by the Anti-Injunction Act.
August 12, 2020
The U.S. Supreme Court should affirm the Sixth Circuit's rejection of a microcaptive insurer's challenge to Internal Revenue Service reporting requirements because a federal statute prohibiting suits from restraining tax collections also covers tax guidance, a law professor said.
July 22, 2020
Several groups including the Cato Institute and U.S. Chamber of Commerce asked the U.S. Supreme Court Wednesday to allow an insurance company's challenge to an IRS notice on microcaptive insurance arrangements, saying it shouldn't be barred by the Anti-Injunction Act.