The Commissioner’s Corner provides material relevant to the Modoc Interaction with other government branches as well as updates on current issues pertaining to captives.
In a 54-page opinion U.S. District Judge Lee H. Rosenthal has struck down a portion of the IRS January 14, 2025 Rule designating IRC 831(b) captives as listed transactions. This is a major victory for the captive industry, and the Domicile applauds the Plaintiffs in the ongoing battle to curb the IRS’s over-reaching in its improper efforts to regulate 831(b) transactions.