( April 18, 2025, 8:47 AM EDT) -- KNOXVILLE, Tenn. — Invoking both the Administrative Procedure Act (APA) and the Protecting Americans from Tax Hikes Act of 2015 (PATH Act), a captive insurance manager filed a complaint in a federal court in Tennessee challenging an Internal Revenue Service final rule targeting small captive tax avoidance schemes, requesting that the regulation be set aside as unlawful, arbitrary and capricious and an overreach of statutory authority....