FTB Announces Resolution for Certain Abusive Transactions Public Service Bulletin

June 19, 2023

Purpose of Bulletin

To inform taxpayers that FTB issued FTB Notice 2023-02, Resolution of Micro-Captive Insurance Transactions and Syndicated Conservation Easement Transactions, on May 31, 2023.


FTB Notice 2023-02 allows taxpayers who have reported tax benefits from two specific abusive transactions to enter into a closing agreement to reverse the tax benefits from the transactions and pay the required additional taxes. Taxpayers who properly complete the closing agreement and adhere to all requirements will receive reduced penalties.

Letters will be sent to identified taxpayers inviting them to participate in this resolution. However, participation is not limited to those who have received an invitation letter and is open to any eligible taxpayer who wishes to participate.

Additional Information

Eligible taxpayers must submit a complete and signed closing agreement from July 10, 2023, through November 17, 2023, and do either of the following:

  • Pay all additional taxes, applicable penalties, and interest by November 17, 2023
  • Enter into an installment agreement to pay all additional taxes, applicable penalties, and interest over a period not to exceed 12 months.

Taxpayer Inquiries

 For more information regarding the notice, go to ftb.ca.gov  and search for resolution of transaction.


Email taxshelter@ftb.ca.gov or call 916-845-3030.