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Tax Court Rules Against Micro-Captive Case Backed by Life and Annuity Assets The judge put off deciding whether to apply a 40% penalty related to economic substance questions.

A Tax Court judge is figuring out how to apply a relatively new, 40% "lack of economic substance" penalty to a micro-captive case.

www.thinkadvisor.com/2025/08/18/t...

@irs #microcaptives #microcaptive #hcera #lackofeconomicsubstance #annuity #life insurance

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IRS identifies certain transactions that are the same as, or similar to, microcaptive insurance transactions as listed transactions and other microcaptive transactions as transactions of interest, both being reportable transactions. buff.ly/42cedkc #microcaptive #IRS

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