The Office of Chief Counsel of the Internal Revenue Service (IRS) has revealed its plans to hire as many as 200 new attorneys as part of the agency’s contest with “syndicated conservation easements, abusive micro captive insurance arrangements and other tax schemes”. The IRS notes that the positions are available around the US in large business, international, small business, self-employed and technical positions. The new hires will help the IRS manage its increasing caseload of corporate and partnership audits against what it considers to be abusive tax schemes, arguing that these arrangements generally lack a legitimate business purpose. This includes micro captives, which returned to the IRS’ ‘Dirty Dozen’ list of tax scams and abusive arrangements in 2021 as the agency contended that the entities commonly lack “many of the necessary attributes of insurance”. In addition, the IRS pointed to high premiums and niche risk coverage as apparent further evidence that micro captives have no connection to genuine business and insurance needs. IRS commissioner Chuck Rettig comments: “Combating abusive tax transactions that threaten to undermine our tax system remains a top priority for our enforcement efforts. It is critical we work to ensure a fair tax system and adding these new attorneys will help us in our ongoing efforts in this arena.”
