Tax Blog

Effective January 14, 2025, the Treasury Department issued final regulations requiring disclosures by certain taxpayers and material advisors involved in a micro-captive listed transaction or transaction of interest. The original due date for making initial disclosures was April 14, 2025, but the IRS provided relief from penalties if such initial disclosures are filed by July 31, 2025. However, such taxpayers and material advisors may have to disclose the transaction if the statute of limitations for an original or amended tax return did not end on or before January 14, 2025.