The Department of the Treasury and the IRS recently issued Notice 2016-66, identifying a certain type of captive insurance company as a “transaction of interest”. Taxpayers that participate in a “transaction of interest” are required to file a Form 8886 with the IRS. Material Advisors are required to file a Form 8918. We have prepared a technical memorandum summarizing the provisions of Notice 2016-66.
CLICK HERE for a copy of our Technical Memorandum on Notice 2016-66. In addition, you are strongly encouraged to consult your independent legal and tax advisors.