N-2016-66: Transaction of Interest -- Section 831(b) Micro-Captive Transactions

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November 1, 2016

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Issue Number: N-2016-66

Inside This Issue

Notice 2016-66 identifies certain “micro-captive transactions” and substantially similar transactions as transactions of interest for purposes of § 1.6011-4(b)(6) of the Income Tax Regulations and §§ 6111 and 6112 of the Internal Revenue Code. This notice also alerts persons involved in such transactions to certain responsibilities and penalties that may arise from their involvement with these transactions.

It will appear in IRB 2016-47 dated Nov. 21, 2016.

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