WebDec 1, 2024 · On March 27, 2024, Petitioner CIC Services, an advisor to taxpayers engaging in micro-captive transactions, sued the IRS and the Treasury Department in federal court, alleging that the IRS promulgated Notice 2016-66 in violation of the Administrative Procedure Act (“APA”). The Petitioner asked the court to stop the IRS … WebInternal Revenue Service (IRS) Notice 2016–66 requires taxpayers and “material advisors” like petitioner CIC to report information about certain insurance agreements called micro-captive transactions. The consequences for noncompliance … Abbreviation of Record. Pub. L. 85–791, Aug. 28, 1958, 72 Stat. 941, which …
Supreme Court Hands Tax Advisor Big Win in CIC …
WebMay 17, 2024 · CIC Services’ estimated compliance costs alone “could well exceed, or even dwarf,” any applicable tax penalties, the Court noted. In fact, following the Anti-Injunction Act’s requirements of violating the notice and then suing to recover any penalty tax levied would “practically necessitate” a pre-enforcement, rather than a refund ... WebJun 10, 2024 · Supreme Court decision in CIC Services v. IRS may open the door to a host of pre-enforcement challenges to IRS reporting requirements under IRS issued Notice 2016-66, interest transaction that the ... grafana access dashboard without login
CIC Services, LLC v. Internal Revenue Service: Captive Insurance …
WebAug 28, 2024 · Otherwise, a taxpayer could simply No. 18-5019 CIC Services, LLC v. IRS, et al. Page 4 “characterize” a challenge to a regulatory tax as a challenge to only the regulatory aspect of the tax and thereby evade the AIA. Fla. Bankers, 799 F.3d at 1071. And “as the Supreme Court has explained time and again . . . the [AIA] is more than a ... WebJun 2, 2024 · The U.S. Supreme Court recently rendered a unanimous opinion holding that the Anti-Injunction Act (AIA) did not block a lawsuit brought by CIC Services against the … WebCIC Services have said the Internal Revenue Service (IRS) is behaving like... MORE. Thursday, February 24, 2024 . ... Tags: CIC Services, CIC Services vs IRS, IRS, Sean King. Captive manager CIC Services has filed a motion for injunctive relief with... MORE. Monday, July 26, 2024 . grafana access denied to this dashboard