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CPA Poses Questions to IRS on Reporting Micro-Captive Deals

NOV. 7, 2016

CPA Poses Questions to IRS on Reporting Micro-Captive Deals

DATED NOV. 7, 2016
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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
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