3 September 2019Law & regulation

CIC vows to take IRS battle to the Supreme Court


CIC Services has warned the Internal Revenue Service that its battle against the tax authority’s “abuse of law-abiding taxpayers is not over,” vowing to take its case all the way to the Supreme Court.

On August 28 the Sixth Circuit denied CIC’s petition for a review of a case originally heard in 2017. That case had seen CIC file a lawsuit against the IRS seeking an injunction from the federal district court to prohibit the enforcement of Notice 2016-66, which was denied.

In the recent hearing seven judges voted in favour of a review and nine voting against.

Sean King, principal and in house counsel at CIC Services, said: “We are thrilled to have received a compelling dissenting opinion in our favor in which those seven judges expressed severe doubts about the soundness of the original 2-1 panel decision against us, and indicated their strong preference to rehear the case.”

Even one of the judges who voted against the review on technical grounds wrote separately to say that the Sixth Circuit panel's original 2-1 decision against CIC was almost certainly wrong, he added.

King expressed hope that the Supreme Court would hear CIC’s case, and noted that “based on its 9-0 precedent in the Direct Marketing case, we expect to win if it does.”


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19 February 2020   For the first time in a long while rates are on the rise across almost all classes of business. Although it may not seem like it to the insurance buyer, many insureds have long been beneficiaries of an artificially soft market. Now, SMEs are assessing their options, and there are several potentially attractive ones in the captives space, says Nate Reznicek of CIC Services.
Law & regulation
30 August 2019   The US Court of Appeals for the Sixth Circuit has declined to review the case of CIC Services versus the Internal Revenue Service (IRS), which was found in favour of the IRS in 2017.

More on this story

Feasibility studies analysis
19 February 2020   For the first time in a long while rates are on the rise across almost all classes of business. Although it may not seem like it to the insurance buyer, many insureds have long been beneficiaries of an artificially soft market. Now, SMEs are assessing their options, and there are several potentially attractive ones in the captives space, says Nate Reznicek of CIC Services.
Law & regulation
30 August 2019   The US Court of Appeals for the Sixth Circuit has declined to review the case of CIC Services versus the Internal Revenue Service (IRS), which was found in favour of the IRS in 2017.