a-23-11, micro-captive transactions

Announcement 2023-11 will be released in conjunction with proposed regulations identifying certain micro-captive transactions as listed transactions, and certain other micro-captive transactions as transactions of interest. The announcement explains that the regulations are being proposed in light of certain court decisions holding that the APA requires the IRS to identify listed transactions through notice-and-comment rulemaking, and that the IRS intends to issue further regulations identifying other listed transactions, to be finalized in 2023.

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