Procedure provided in response to comments received on regulations identifying micro-captive listed transactions and micro-captive transactions of interest
The IRS released Rev. Proc. 2025-13 that provides a streamlined procedure for a taxpayer that has elected the application of the alternative tax for certain non-life insurance companies under section 831(b) to obtain the automatic consent of the Secretary of the Treasury or her delegate to revoke such election.
As indicated in the preamble to the final regulations identifying certain micro-captive transactions as listed transactions and certain other micro-captive transactions as transactions of interest (read TaxNewsFlash), the IRS issued Rev. Proc. 2025-13 in response to comments received on the proposed regulations adopted by those final regulations.