TAX AND ADMINISTRATIVE LAW

The IRS acknowledged that some microcaptive insurance transactions were not abusive but claimed a lack of sufficient information to discern which such transactions were abusive and which were not. Because micro-captive insurance transactions are now reportable transactions, material advisors who assist and advise taxpayers with respect to such transactions must maintain certain records and report certain information about their clients to the IRS. [...]CIC Services contends that the defendants violated the Congressional Review Act, which requires agencies to submit certain rules and regulations to Congress for its review before they become effective. [...]because CIC Services' challenge would at least temporarily nullify a potential tax if successful, the majority agreed with the district court that the AIA bars CIC Services' suit from moving forward. [...]Judge Amul Thapar dissented on behalf of himself and six others.