Date: 2023-04-11
Links to Federal Register: HTML, PDF
Document Number: 2023-07315, RIN: 1545-BQ44
Action: Notice of proposed rulemaking and notice of public hearing.
Abstract: This document contains proposed regulations that identify transactions that are the same as, or substantially similar to, certain micro-captive transactions as listed transactions, a type of reportable transaction, and certain other micro-captive transactions as transactions of interest, another type of reportable transaction. Material advisors and certain participants in these listed transactions and transactions of interest are required to file disclosures with the IRS and are subject to penalties for failure to disclose. The proposed regulations affect participants in these transactions as well as material advisors. This document also provides notice of a public hearing on the proposed regulations.
| Notable phrases | Frequency |
|---|---|
| captive | 284 |
| transaction(s) of interest | 88 |
| micro-captive | 83 |
| loss ratio | 76 |
| material advisor | 47 |
| loss ratio factor | 32 |
| loss ratio computation period | 19 |
| substantially similar to | 16 |
| form 8886 | 14 |
| transaction of interest computation | 13 |
| less than 65 percent | 10 |
| existence for less than five taxable years | 6 |
| Reg. Cites | Frequency |
|---|---|
| 1.6011-11(c) | 14 |
| 1.6011-4(d) | 13 |
| 1.6011-4 | 10 |
| 1.6011-10 | 8 |
| 1.6011-4(b)(2) | 8 |
| 1.6011-4(b)(6) | 8 |
| 1.6011-10(c)(2) | 8 |
| 1.6011-10(a) | 7 |
| 1.6011-11 | 7 |
| 1.6011-10(d)(2) | 6 |
| 1.6011-10(c)(1) | 6 |
| 1.6011-10(c) | 6 |
| 1.6011-11(a) | 5 |
| 1.6011-10(e)(2) | 5 |
| 1.6011-11(d)(2) | 5 |
| 1.6011-4(e) | 5 |
| 1.6011-11(e)(2) | 5 |
| 1.6011-10(b) | 4 |
| 1.6011-10(b)(1)(iii) | 4 |
| 301.6111-3(b) | 3 |
| Sec. Cites | Frequency |
|---|---|
| 831(b) | 23 |
| 6011 | 11 |
| 6111 | 8 |
| 6112 | 3 |
| 6011(a) | 3 |
| 6501(c)(10) | 3 |
| 6662A | 3 |
| 6707A | 3 |
| 162 | 3 |
| 953(d) | 3 |
| 267(b) | 3 |
| 831(a) | 3 |
| 2718(b) | 2 |
| 6708(a) | 2 |
| 833(c)(5) | 2 |
| 501(c)(15) | 2 |
Statistics
Number of pages: 18, words: 18,481, sentences: 556
Average words per sentence: 33