IRS Microcaptive Transaction- Of-Interest Designation Upheld And Deemed Reasonable

( July 9, 2026, 9:06 AM EDT) -- DALLAS — A Texas federal judge denied a tax firm’s bid to vacate the IRS’s transaction-of-interest designation for certain microcaptive insurance arrangements and granted the government summary judgment in part in the firm’s Administrative Procedure Act (APA) challenge to the agency’s final disclosure rule, holding that an intervening ruling mooted part of the challenge and that the remaining transaction-of-interest criteria reasonably identified microcaptive arrangements with a potential for tax avoidance....