IRS Statement on micro-captive letter response relief


Notice: Historical Content

This is an archival or historical document and may not reflect current law, policies or procedures.

Updated: August 17, 2020

Letter 6336 requests that taxpayers review their micro-captive insurance filing positions and notify the IRS in writing by the response due date stated in the letter, if they have discontinued taking deductions or other tax benefits from a micro-captive insurance transaction. The letter also encourages taxpayers to consult with an independent tax advisor in regard to prior year filing positions and consider filing amended returns to bring themselves back into compliance if warranted. The letter provides a hotline number for taxpayers to contact us.

The IRS understands that due to the current conditions, taxpayers may need additional time beyond the stated response due date to provide their written response. As such, the IRS is automatically extending the May 4 due date to June 4, 2020. Those who received the letter need not reach out to us to confirm the extension. Taxpayers who received a letter with response due date after May 4, 2020 and who need additional time should call the hotline number included in the letter. The IRS will continue to monitor the situation, including the impact of current operations.