Understanding The IRS Settlement Initiative Offer For Targeted 831(b) Captive Insurance Companies
It’s important to understand that the IRS has extended this offer to only 200 taxpayers. There are at least 2,000 captive arrangements that are under audit and probably well north of 10,000 captive arrangements that may ultimately come under scrutiny by the IRS.
The offer will not be extended to captive arrangements and their owners “with pending docketed years under IRS Counsel’s jurisdiction.”