Tax Consultancy Asks 5th Circ. To Kill Microcaptive Rule

By Kevin Pinner · October 29, 2026, 5:12 PM EDT

The IRS never published data showing that microcaptive transactions pose a potential for tax avoidance to justify a rule making companies and advisers report them as "transactions of interest," a tax...

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Documents

Case Information

Case Title

Ryan v. IRS

Case Number

26-10708

Court

Appellate - 5th Circuit

Nature of Suit

2899 Other Statutes

Date Filed

July 31, 2026