CIC Services backs lobbying group to tackle IRS “abuse” on micro captives


CIC Services backs lobbying group to tackle IRS “abuse” on micro captives


CIC Services, the Tennessee-based captive manager at the heart of battles with the US Inland Revenue Service over disclosure of microcaptive arrangements, is seeking to establish a lobbying campaign to challenge the regulator’s approach.

In an appeal to captive supporters, the company accuses the IRS of spreading “fear, uncertainty, and doubt” (FUD) in the industry and among potential captive users.

“The IRS’ FUD campaign fails to discriminate between legitimate and truly abusive captive arrangements and fails to offer the industry or IRS agents any meaningful guidance in distinguishing between the two,” the firm writes.

“Nevertheless, the industry’s resistance against the IRS’ FUD campaign has resulted in a Supreme Court victory, the district court’s issuance of a preliminary (and hopefully soon to be permanent) injunction against the IRS and now the IRS’s complete acquiescence in cases like Puglisi Egg Farms

It adds: “[W]e believe that now is the perfect time to organize a lobbying effort designed to demonstrate to Congress that the IRS is actively subverting its public policy as codified in Section 831(b) and to persuade Congress to do something about it.”

A letter sent by attorneys Kenneth Lazarus and James Perna, comanagers of Minicap LLC, which will lead the lobbying effort, asks contributors for $500 to join the group and four quarterly payments of $5,000.

“For this effort to be successful, we’ll need the financial participation of several industry participants,” the appeal reads. “The proposed cost per participant isn’t cheap, but it’s manageable for most and amounts in most cases to less than the annual fees earned on only one or two captives. Even if we are unsuccessful in obtaining direct Congressional intervention, we believe that informing Congress of these IRS abuses will ultimately pay dividends in many other ways.”

Those interested are asked to email Bryan Ridgway at or

CIC Services, effort, IRS, micro captives, intervention, congressional

Captive International