- Loss ratio for “listed transactions” reduced to 30%
- Revenue Procedure 2025-13 introduced to streamline revoking 831(b) election
- IRS perceived by some to be removing 831(b) by stealth
- Ryan LLC court case lodged against IRS after final regs published
Despite the Internal Revenue Service making some concessions in its long-awaited final version of 831(b) regulations, particularly in relation to loss ratio thresholds, industry commentators believe it continues to target micro captives unfairly, with one legal challenge already filed.
The finalised regulations will appear in the Federal Register on 14 January, with regulations generally taking effect 30-days after publication in the Federal Register.
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