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Nuts and Bolts of Micro-Captive Examinations
Tuesday, May 7 at 12pm (CST)
Speakers:
Naveid P. Jahansouz, J.D.
Cody R. Gackle, J.D., LL.M.
About this Webinar
Overview
This presentation discusses current efforts by the IRS to crackdown on micro-captive insurance transactions. We will review some of the Tax Court cases involving micro-captives, as well as the proposed regulation to make certain micro-captive transactions “listed transactions” and certain other micro-captive transactions “transactions of interest.” We will also discuss the posture IRS has taken in micro-captive examinations, as well as the ongoing settlement program.
Key Topics
Description of what a micro-captive transaction is and why IRS views it as potentially abusive.
Summary of caselaw.
Notice 2016-66 and new proposed regulation.
IRS Examinations and the 2020 Micro-Captive Insurance Resolution Terms.
Details
Course Level: Intermediate
Prerequisite: None
Cost: Free
CPE and MCLE Credit Info:
Course Number: 174232587
CPE Credit: 1.20 Hrs.
MCLE Credit: 1.00 Hr.
CFP Credit Info:
CFP Course Number: 324102
CFP Credit: 1.00 Hr.
About the Speakers
Naveid P. Jahansouz, J.D.
Associate
Mr. Jahansouz’s practice focuses on income tax litigation, white collar and government regulatory litigation, and real estate matters. He represents individuals and businesses in all stages of federal tax controvery matters, including examinations with the IRS, administrative appeals, Private Letter Rulings, employment tax matters, voluntary disclosures, offshore compliance, promoter investigations, penalty abatements, and litigation. In the white-collar crime area, his practice focuses on tax crimes as well as other financial crimes such as money laundering, bankruptcy fraud, wire fraud, mortgage fraud, and structuring. He has represented Qualified Opportunity Funds and Real Estate Investment Trusts in obtaining late election relief through Private Letter Rulings. He also has significant experience with defending micro-captive insurance transactions.
Prior to joining the firm in 2023, Mr. Jahansouz was a Tax Controversy Senior Manager with one of the nation’s largest full-service advisory and accounting firms, where he represented large companies and high net worth individuals in IRS tax controversy matters. Prior to that, he was a Senior Associate with a Fort Worth law firm where he worked on civil and criminal tax matters.
Mr. Jahansouz was admitted to practice in Texas in 2011.
Read his full bio here. You can contact Mr. Jahansouz at 214-749-2430 or by email at njahansouz@meadowscollier.com.
Cody R. Gackle, J.D., LL.M.
Associate
Ms. Gackle practices in the areas of Income Tax Litigation, Estate and Gift Tax Litigation, White Collar and Government Regulatory Litigation, and Income Tax and Business Planning. She represents individuals and businesses in all stages of tax disputes, including examinations with the Internal Revenue Service, administrative appeals, voluntary disclosures, and litigation. Ms. Gackle’s practice also concentrates on white-collar crime such as securities, tax and bank fraud. Her tax planning practice includes federal, state and international tax planning for individuals and businesses seeking to minimize tax obligations.
Ms. Gackle served as a Legal Intern for The Honorable Andrea Thompson of the 416th District Court in Plano, TX. She also served as a Legal Extern for the IRS Chief Counsel, Small Business/Self-Employed Division in Dallas, TX.
Ms. Gackle was admitted to practice in Texas in 2021.
Read her full bio here. You can contact Ms. Gackle at 214-744-2430 or by email at cgackle@meadowscollier.com.