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Tax Notes Federal: Firm Says Proposed Microcaptive Regs Are Overbroad

June 20, 2023

United States
United States
United States

In this comment letter published by Tax Notes Federal, Eversheds Sutherland Partner Saren Goldner warns that proposed regulations (REG-109309-22) identifying some microcaptive transactions as listed transactions are overbroad and if adopted as written could cause companies properly characterized as insurance companies for federal tax purposes to be subject to the reportable transaction information reporting rules.

 

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Key contacts

sarengoldner@eversheds-sutherland.com

Saren Goldner

Partner

New York, United States

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