IRS Asks 5th Circuit To Reinstate Microcaptive Listed-Transaction Rule

( October 29, 2026, 8:42 AM EDT) -- NEW ORLEANS — The IRS and Treasury Department urged the Fifth Circuit U.S. Court of Appeals to uphold reporting requirements for certain microcaptive insurance arrangements and reinstate a stricter designation vacated by a Texas federal judge, arguing that the agency reasonably identified characteristics associated with tax avoidance and was not required to prove that most covered transactions were abusive....