Source article by Caplin & Drysdale via International Law Office 03.03.2017
On November 1 2016 the Internal Revenue Service (IRS) issued Notice 2016-66, which identifies certain transactions relating to micro-captive insurers as ‘transactions of interest’.
This designation brings covered captive insurers into a federal reporting regime that requires participants in such transactions, as well as their advisers, to meet certain one-off and annual filing obligations.
Participants and advisers should also be aware that several states have similar reporting obligations, and failure to comply with the state reporting regimes can lead to significant penalties.
The content, form and deadline for reporting vary from state to state.
Participants and material advisers should therefore give due consideration to the state reporting requirements and use the next few months to ensure compliance with all applicable reporting regimes.