CPA Poses Questions to IRS on Reporting Micro-Captive Deals
CPA Poses Questions to IRS on Reporting Micro-Captive Deals
- AuthorsGiordano, Diane
- Institutional AuthorsMarcum LLP
- Cross-Reference
- Code Sections
- Subject Area/Tax Topics
- Industry GroupsInsurance
- Jurisdictions
- LanguageEnglish
- Tax Analysts Document NumberDoc 2016-24841
- Tax Analysts Electronic Citation2016 TNT 247-17
From: Giordano, Diane [mailto:Diane.Giordano@marcumllp.com]
Sent: Monday, November 07, 2016 3:29 PM
To: Notice Comments
Subject: Notice 2016-66
Hello
I have been reviewing Notice 2016-66 and have some questions related to timing and application.
As you can guess, consulting firms are bombarding clients indicating their expertise in complying with the notice.
I am trying to make sure I understand the requirements.
In accordance with Section 3: Rules of Application, it seems that only captives created after November 2, 2006 are affected by the Notice. Therefore, if a client created a captive in 2003, this would not apply.
While the notice indicates transactions and computation period and possible penalties, the notice does not seem to describe how to file a disclosure statement, other than reporting by using form 8886, in which it indicates is due by January 30, 2017.
Also due on the same date, are comments related to this notice. Can the disclosure be required at the same time the IRS is asking for comments?
Diane Giordano, CPA
Partner
Marcum LLP
10 Melville Park Rd
Melville, NY 11747
P: (631) 414-4532
F: (631) 414-4533
Diane.Giordano@marcumllp.com
- AuthorsGiordano, Diane
- Institutional AuthorsMarcum LLP
- Cross-Reference
- Code Sections
- Subject Area/Tax Topics
- Industry GroupsInsurance
- Jurisdictions
- LanguageEnglish
- Tax Analysts Document NumberDoc 2016-24841
- Tax Analysts Electronic Citation2016 TNT 247-17