CIC Services, LLC et al v. Internal Revenue Service et al
Case Number:
3:17-cv-00110
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July 14, 2023
Judge Urges No Atty Fee Award In IRS Microcaptive Row
A microcaptive insurance advisory firm should not be awarded attorney fees after prevailing against the IRS in a long-running challenge to guidance requiring the disclosure of microcaptive transactions because the agency's position against the firm was substantially justified, a federal magistrate judge has recommended.
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December 22, 2022
Top Federal Tax Cases Of 2022
During a consequential year, the U.S. Supreme Court allowed a House panel to get former President Donald Trump's tax returns and found the U.S. Tax Court could hear a firm’s day-late challenge regarding a levy it faced. Here, Law360 reviews some of the most significant federal tax decisions of 2022.
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September 23, 2022
IRS Drops 6th Circ. Challenge To Voided Microcaptive Notice
The IRS won't challenge a Tennessee federal court's decision setting aside an agency notice requiring the disclosure of microcaptive insurance arrangements, according to an order from the Sixth Circuit on Friday dismissing appeals from the agency and an advisory firm.
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July 08, 2022
Top 5 International Tax Cases Of 2022: Midyear Report
Significant international tax rulings during the first half of 2022 invalidated IRS regulations for skipping the public comment requirement while showing little leniency for those accused of tax crimes. Meanwhile, courts in Germany upheld and imposed jail sentences for Warburg banking executives enmeshed in the dividend-stripping practice known as cum-ex. Here, Law360 examines the notable international tax rulings in the first half of 2022.
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June 02, 2022
Court Walks Back Requiring IRS To Return Microcaptive Docs
A Tennessee federal court walked back an order requiring the IRS to return documents it received under a now-invalidated notice requiring the disclosure of microcaptive insurance arrangements, saying Thursday that it can't force the agency to give back the records.
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May 09, 2022
Returning Docs To Taxpayers Would Come At A Cost, IRS Says
A microcaptive insurance company wrongly argues that the Internal Revenue Service will not suffer irreparable harm if it returns documents that taxpayers sent to comply with a now-invalidated notice requiring disclosure of microcaptive transactions, the government said Monday.
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April 21, 2022
US Urges Judge To Pause Microcaptive Docs Return Order
The U.S. government asked a Tennessee federal judge to pause his order requiring the IRS to return documents it received under a now-invalidated notice requiring disclosure of microcaptive transactions until the court has resolved the government's challenge to that order.
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April 19, 2022
US Says Court Can't Force IRS To Return Microcaptive Docs
A Tennessee federal court shouldn't force the IRS to return records it received under a now-invalidated notice requiring the disclosure of microcaptive insurance arrangements, the U.S. said, arguing the court lacked the power to compel the documents' return.
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March 21, 2022
Court Tosses IRS Microcaptive Reporting Requirements
A Tennessee federal judge set aside an IRS notice requiring the disclosure of microcaptive insurance arrangements, saying Monday that the agency hadn't justified its decision to flag the transactions as potentially abusive and shirked its public feedback obligations.
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March 11, 2022
IRS Microcaptive Guidance Not Necessarily Void, Court Told
A recent Sixth Circuit decision invalidating Internal Revenue Service reporting guidance for potentially abusive benefit trust arrangements doesn't necessarily require a Tennessee federal court to void similar requirements for microcaptive insurance companies, the government said Friday.