irs notice 2017-66

obsoleting Notice 2016-66 (as modified by Notice 2017-8) and will not enforce the disclosure requirements or penalties that are dependent upon the procedural validity of Notice 2016-66

Notice 2016-66 The Department of the Treasury (“Treasury Department”) and the Internal Revenue Service (the “IRS”) are aware of a type of transaction described below in which a taxpayer attempts to reduce the aggregate taxable income of the taxpayer related persons or both using contracts that the parties treat as insurance contracts

Department”) and the Internal Revenue Service (the “IRS”) released Notice 2016-66 2016-47 I R B 745 identifying transactions that are the same as or substantially similar to the transaction described in section 2 01 of Notice 2016-66 as transactions of interest for purposes of § 1 6011-4(b)(6) of the Income Tax Regulations and §§ 6111

Notice 2017-66 SECTION 1 PURPOSE The IRS has identified $379549691 35 of volume cap to be available under this Notice for reallocation to public power 

The Notice was recently modified by Notice 2017-8 to provide that disclosures for prior open tax years should be made by sending Forms 8886 

The IRS today released an advance version of Notice 2016-66 that identifies a type of transaction involving a “micro-captive insurance” structure as a “transaction of interest”—i e a tax avoidance transaction—for purposes of Reg section 1 6011-4(b)(6) and sections 6111 and 6112 Notice 2016-66 [PDF 44 KB] states that these

described in Notice 2016-66 This memorandum also summarizes disclosure rules under Treas Reg § 1 6011-4 for participants as well as under I R C §§ 6111 and 6112 for material advisors as well as associated penalties As a transaction of interest participants and

The 2017 Cumulative List set forth in section IV of this notice lists specific matters the IRS has identified for review in determining whether a defined