IRS Maintains That Captive Final Rule Was Based On Data And Prior Litigation

( February 4, 2026, 7:32 AM EST) -- DALLAS — Stating that “micro-captives can and have been used repeatedly for tax avoidance,” the Internal Revenue Service moved for summary judgment in a tax firm’s challenge to a final rule on microcaptive insurance arrangements, asserting that the factors used in identifying potential avoidance schemes were based on data and prior litigation and that the tax firm conflates disclosure requirements with disallowance....

IRS Maintains That Captive Final Rule Was Based On Data And Prior Litigation

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