On August 3, 2023, the Department of the Treasury and the IRS issued proposed regulations identifying certain monetized installment sales transactions and substantially similar transactions as listed transactions that must be reported to the IRS using IRS Form 8886. Material advisors and certain participants are also required to file disclosures with the IRS. Previously, in April, 2023, the Treasury and the IRS used proposed regulations to identify certain micro-captive arrangements as listed transactions and others as transactions of interest.
