WebJul 14, 2024 · In 'CIC Services', the U.S. Supreme Court unanimously rejected the government’s argument that the Anti-Injunction Act barred a challenge to an IRS Notice requiring both taxpayers and their ...
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WebSep 21, 2024 · In CIC Services LLC v. Internal Revenue Service, Knoxville, Tennessee-based CIC Services sued to stop an IRS reporting requirement for microcaptives, which are often known as 831(b) captives. WebMay 18, 2024 · CIC Services, LLC v. IRS, et al., 925 F.3d 247, 257 (6th Cir. 2024). Justice Kagan, writing for the Court, reversed and held that CIC’s suit is “not a suit ‘for the purpose of restraining the [IRS’s] assessment of collection’ of a tax, and so does not trigger the Anti-Injunction Act.” CIC Services, LLC v.
WebBy contrast, CIC’s suit targets neither a regulatory tax nor a revenue-raising one; CIC’s action challenges a reporting mandate separate from any tax. Because the IRS chose to address its concern about micro-captive agreements by imposing a reporting requirement rather than a tax, suits to enjoin that requirement fall outside the Anti ... WebDec 1, 2024 · On March 27, 2024, Petitioner CIC Services, an advisor to taxpayers engaging in micro-captive transactions, sued the IRS and the Treasury Department in …
WebJun 2, 2024 · The U.S. Supreme Court recently rendered a unanimous opinion holding that the Anti-Injunction Act (AIA) did not block a lawsuit brought by CIC Services against the … WebMay 8, 2024 · The Risk & Treasury article “Challenging the IRS … and Winning” by Sean King discusses the case of CIC Services, which took on the IRS and won in a landmark Supreme Court decision. CIC Services challenged the validity of IRS Notice 2016-66, which required certain taxpayers to disclose information about captive insurance transactions, …
WebSUPREME COURT OF THE UNITED STATES _________________ No. 19–930 _________________ CIC SERVICES, LLC, PETITIONER v. INTERNAL REVENUE …
WebJun 10, 2024 · On Tax Day, May 17, 2024, in a unanimous opinion authored by Justice Kagan, the United States Supreme Court held that the Anti-Injunction Act (AIA) does not … sic code for car dealershipWebMar 24, 2024 · In CIC Services, LLC v. IRS, 1 the U.S. District Court for the Eastern District of Tennessee invalidated Notice 2016-66 for failing to comply with the Administrative … sic code for cbd retailWebCIC Services have said the Internal Revenue Service (IRS) is behaving like... MORE. Thursday, February 24, 2024 . ... Tags: CIC Services, CIC Services vs IRS, IRS, Sean King. Captive manager CIC Services has filed a motion for injunctive relief with... MORE. Monday, July 26, 2024 . sic code for customer serviceWebFeb 23, 2024 · collection of tax, which has resulted in federal court opinions that are difficult to reconcile. CIC Services v. Internal Revenue Service At issue in CIC Services, which is on appeal from the Sixth Circuit, is whether the TAIA precludes pre-enforcement judicial review of IRS Notice 2016-66 (Notice). CIC Services (CIC) claims that the IRS the period when fiction prevailed over poetryWebAug 28, 2024 · Otherwise, a taxpayer could simply No. 18-5019 CIC Services, LLC v. IRS, et al. Page 4 “characterize” a challenge to a regulatory tax as a challenge to only the regulatory aspect of the tax and thereby evade the AIA. Fla. Bankers, 799 F.3d at 1071. And “as the Supreme Court has explained time and again . . . the [AIA] is more than a ... the period when dinosaurs diversify isWebJul 14, 2024 · In 'CIC Services', the U.S. Supreme Court unanimously rejected the government’s argument that the Anti-Injunction Act barred a challenge to an IRS Notice … sic code for dairy farmWebDec 1, 2024 · On March 27, 2024, Petitioner CIC Services, an advisor to taxpayers engaging in micro-captive transactions, sued the IRS and the Treasury Department in federal court, alleging that the IRS promulgated Notice 2016-66 in violation of the Administrative Procedure Act (“APA”). The Petitioner asked the court to stop the IRS … the periods of the periodic table