Taxpayers and advisors affected by this Notice must attend this webinar to learn the new requirements that must be satisfied by January 30, 2017.

Free CPE Webinar

WEDNESDAY, November 30, 2016

12:00 – 1:00 PM CST


On November 1, 2016, the IRS issued Notice 2016-66, which makes a significant number of captive insurance arrangements “Transactions of Interest” and thereby subjects these arrangements to detailed reporting obligations. Under the Notice, captive insurance companies, insured parties and certain owners, and other involved parties and advisors (including captive managers) will have to meet certain disclosure and recordkeeping requirements. By January 30, 2017, parties that have entered into these “Transactions of Interest,” potentially going back to 2006, will have to file a disclosure statement with the IRS detailing many of the facts surrounding their involvement in the captive arrangement. Similarly, captive managers and other advisors have new reporting and recordkeeping requirements with respect to the arrangements. The disclosures will be utilized by the IRS for various purposes including possible guidance and enforcement.

Failure to file a complete and accurate disclosure statement carries a heavy penalty. Taxpayers will face a penalty of 75% of the decrease in tax as a result of the transaction, with a maximum penalty up to $50,000. Captive managers and other advisors are subject to a $50,000 penalty for each failure to file and a penalty of $10,000 per day after the 20th day of not filing an information list requested by the IRS. The stiff penalties make it imperative that those affected pay close attention to the specific requirements imposed by the Notice. Attend our CPE webinar to learn more and to ensure you are in line with all IRS requirements.

Our panel will include:

  • Former IRS Acting Commissioner and alliantgroup National Director of Tax, Steven Miller
  • Former IRS Commissioner of Small Business/Self-Employed Division (SB/SE) and alliantgroup Director of IRS Practice & Procedure, Kathy Petronchak
  • Former Senior Technical Advisor for the Commissioner of Tax Exempt and Government Entities (TEGE) Division and the Large and Mid-Size Business Division at the IRS, Ron Schultz

Have questions or comments? Email [email protected]