IRS Extends Reporting Requirements for Certain Micro-Captives

The IRS issued Notice 2025-24, offering significant penalty relief for participants and material advisors involved in micro-captive reportable transactions. This notice extends the deadline for filing disclosure statements, originally due April 14, 2025, to July 31, 2025, extending the window for compliance without penalty.

Issue Number: N-2025-24

Notice 2025-24 provides relief from penalties under section 6707A(a) and 6707(a) for participants in and material advisors to micro-captive reportable transactions for disclosure statements required to be filed with the Office of Tax Shelter Analysis (OTSA) under sections 6011 and 6111, as set forth in §§ 1.6011-10(h)(2) and (3) and 1.6011-11(h)(2) and (3), respectively. This relief applies only if the required disclosure statements are filed with OTSA by July 31, 2025.

Notice 2025-24 will be in IRB: 2025-19, dated May 5, 2025.

Get In Touch

We understand that this update may raise questions. We are committed to providing you with timely and accurate information and will continue to monitor tax developments closely. We are prepared to assist you in navigating evolving regulations. If you’re interested in learning more about Johnson Lambert’s comprehensive tax services or have specific questions about how we can support your organization’s tax needs, contact us today.