IRS Notice: Penalty Waiver for Micro-Captive Reportable Transactions (IRC §6707A)

The IRS issued a notice providing relief for penalties under section 6707A(a) of the Internal Revenue Code for participants in micro-captive reportable transactions that fail to file the disclosure statements required under sections 6011 and 1.6011. The relief is only available if the taxpayers file the required disclosure statement with the Office of Tax Shelter Analysis (OTSA) by July 31, 2025. [IRS Notice 2025-24, (April 14, 2025)]

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