On November 4, alliantgroup’s National Director of Tax and former IRS Acting Commissioner Steven Miller was quoted in the Daily Tax Report regarding a notice from the Service with respect to a significant number of micro-captive insurance arrangements.
In Allyson Versprille’s article “Is ‘Micro-Captive’ Insurer Guidance the IRS’s Nuclear Option” Versprille discusses the notice released earlier this month that listed section 831(b) micro-captives as “Transactions of Interest.” Such a designation will require that captive insurance companies, insured parties and certain owners, and other involved parties and advisors (including captive managers) meet certain disclosure and recordkeeping requirements by January 30, 2017 or face heavy penalties. The notice will have a tremendous and immediate impact on the industry, with the article noting that up to 90 percent of 831(b) captives could be affected by the new IRS guidance.
When asked to comment, Miller had this to say with respect to the notice and ongoing captive insurance litigation:
When the guidance was issued, Steven Miller, a former acting IRS commissioner who now works as the national director of tax at Alliantgroup LP, questioned why the agency didn’t wait for the final ruling in an ongoing U.S. Tax Court case, Avrahami v. Commissioner.
On Wednesday, November 30, Steven Miller will be joined by Kathy Petronchak, former IRS Commissioner of the Small Business/Self-Employed Division and alliantgroup Director of IRS Practice & Procedure as well as alliantgroup Managing Director of Tax Controversy John Dies to discuss the new IRS guidance and the steps those involved in micro-captive insurance arrangements should be taking to remain compliant with IRS standards.
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About the Author
In a career devoted to government service, Steven T. Miller has spent the last 25 years with the IRS, serving the agency in a number of diverse and increasingly important roles. He served as former IRS Acting Commissioner in 2012, but prior to that Steven served for several years as the Deputy Commissioner for Services and Enforcement, leading all IRS enforcement and service activity. Steven also served as the Commissioner of the Large and Mid-Size Business Division, overseeing IRS audits of large taxpayers and the IRS programs relating to offshore tax compliance and international tax law enforcement. As the Commissioner of the Tax Exempt and Government Entities Division, he supervised the IRS oversight of governments, tax exempt entities and retirement programs.