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“Abusive micro-captive insurance arrangements” are a key focus for enforcement, the IRS has said as it announced a recruitment drive for tax abuse attorneys.
The Internal Revenue Service said it would seek to “help the agency combat syndicated conservation easements, abusive micro-captive insurance arrangements and other tax schemes” with the hires.
Up to 200 new staff will help the IRS manage the increasing caseload in its multi-year effort to stamp out abusive schemes and ensure those participating pay tax owed and penalties, it said.
Positions will be available around the country and work across various areas, including handling cases in the United States Tax Court and serving on trial teams in the biggest cases.
“This is an excellent opportunity for attorneys with experience in litigation, partnership tax law and planning complex transactions to join the Office of Chief Counsel and make a real difference for our tax system,” said principal deputy chief counsel William Paul.
“Abusive micro-captive insurance arrangements …remain a key focus of IRS enforcement,” its statement added. “These deals are generally sold to owners of closely held entities. The deals commonly lack many of the necessary attributes of insurance, have excessive premiums, insure highly improbable risks and have no connection to genuine business and insurance needs.”
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