WebBy contrast, CIC’s suit targets neither a regulatory tax nor a revenue-raising one; CIC’s action challenges a reporting mandate separate from any tax. Because the IRS chose to address its concern about micro-captive agreements by imposing a reporting requirement rather than a tax, suits to enjoin that requirement fall outside the Anti ... WebJul 14, 2024 · In 'CIC Services', the U.S. Supreme Court unanimously rejected the government’s argument that the Anti-Injunction Act barred a challenge to an IRS Notice requiring both taxpayers and their ...
Victory! U.S. Supreme Court Rules Unanimously Against IRS in CIC
WebJun 23, 2024 · In 2016, the IRS issued Notice 2016-66, directly at issue in CIC Services, which designates certain micro-captive insurance arrangements as “transactions of interest” and compels participants ... WebJul 12, 2024 · that the Court deemed irrelevant in CIC Services, the AIA requires plaintiffs seeking to challenge the validity of a tax to file their lawsuits after paying the disputed tax and filing a claim for refund. In CIC Services, the petitioner, CIC Services, LLC (CIC), brought a lawsuit challenging the “lawfulness” of IRS Notice 2016-66 (Notice). round 845 to the nearest 100
Supreme Court in CIC Services LLC v. IRS Allows Material Advisor …
WebInternal Revenue Service (IRS) Notice 2016–66 requires taxpayers and “material advisors” like petitioner CIC to report information about certain insurance agreements called micro-captive transactions. The consequences for noncompliance … Abbreviation of Record. Pub. L. 85–791, Aug. 28, 1958, 72 Stat. 941, which … WebJun 10, 2024 · Supreme Court decision in CIC Services v. IRS may open the door to a host of pre-enforcement challenges to IRS reporting requirements under IRS issued Notice 2016-66, interest transaction that the ... WebCIC Services v. Internal Revenue Service is a U.S. Supreme Court case involving when courts may accept lawsuits challenging the validity of regulations made by the … strategic employment zone south australia