California Introduces Settlement Proposal for Micro-Captive Insurance Transactions and Syndicated Conservation Easement Transactions. What's the IRS' Plan?
By Joel N. Crouch on June 9, 2023
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Joel N. Crouch
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On May 31, 2023, the California Franchise Tax Board (FTB) issued Notice 2023-02 providing a limited time settlement opportunity to taxpayers who participated in potentially abusive Micro-Captive Insurance (MCI) and Syndicated Conservation Easement (SCE) transactions.
Terms of the settlement proposal are as follows:
Only time will tell.
If you have any tax-related questions, please feel free to contact me at jcrouch@meadowscollier.com.
Terms of the settlement proposal are as follows:
- Eligible taxpayers include those who participated in a MCI or SCE even if they are currently under examination by the FTB or IRS.
- Taxpayers must pay the taxes and interest attributable to the reversal of the tax benefits previously received.
- Taxpayers who have not been contacted by the IRS or FTB will not owe any penalties.
- Taxpayers who have been contacted by the IRS or FTB, but have not received a Notice of Proposed Adjustment, must pay the tax and interest and a 20% penalty.
- Taxpayers who have been contacted by the IRS or FTB and have received a Notice of Proposed Adjustment must pay the tax and interest, a 20% penalty and an interest-based penalty.
- Eligible taxpayers must request to participate in the settlement proposal by submission to the FTB no later than November 17, 2023.
Only time will tell.
If you have any tax-related questions, please feel free to contact me at jcrouch@meadowscollier.com.