N-2025-24: Limited Waiver of Penalties for Certain Disclosure Statements for Micro-captive Reportable Transactions

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.

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