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Volume 53, Number 9 September 2022
TAX CLINIC
Paying for personal
guaranties of company
debts ........................................... 7
Standard mileage rate
increased July 1 .......................... 9
Virtual currency grantor
trusts and ETFs: Tax
compliance ............................... 10
IRS service issues
highlighted in national
taxpayer advocate report .......... 14
Mutual fund-to-ETF
conversion: Tax implications ..... 16
DEPARTMENTS
STATE & LOCAL TAXES ............... 26
TAX PRACTICE
MANAGEMENT ............................ 30
18 Microcaptive insurance arrangements PERSONAL FINANCIAL
after CIC Services PLANNING .................................... 34
By Kaitlin Newkirk and Sarah Webber CASE STUDY ................................ 38
A federal district court recently held that Notice 2016-66, which classifies certain
microcaptive insurance arrangements as transactions of interest that are reportable TAX TRENDS ................................ 42
transactions under Regs. Sec. 1.6011-4, is invalid under the Administrative
Procedure Act. This article discusses the ramifications of the decision for taxpayers
engaging in microcaptive insurance transactions and possible responses to the Tax News
decision by the IRS.
For the latest tax news, visit
TheTaxAdviser.com.
On the cover and above: Images by MirageC/Getty Images
2 September 2022 The Tax Adviser