RECENT ARTICLES ON CAPTIVES
2020.03.25 ... The IRS Sends Soft Warning Letters To Thousands Of 831(b) Risk-Pooled Captive Owners
2020.02.04 ...The IRS Strikes A Rich Seam Of Tax And Penalty Gold In Risk-Pooled 831(b) Captives And Is Sending In More Miners
2019.12.31 ... The Next Generation Captive Insurance Tax Shelter Explained
2019.12.05 ... Bitter Coffee: Starbucks Squabbles With The Washington Insurance Commissioner Over $633 Million Paid To Its Captive Insurance Company
2019.11.17 ... IRS Suggests Criminal Referrals To Be Made In Abusive 831(b) Captive Tax Shelter Cases
2019.09.28 ... Johnson & Johnson Wins Appeal On $60 Million Tax Case To New Jersey For Captive Insurance Company
2019.09.26 ... Understanding The IRS Settlement Initiative Offer For Targeted 831(b) Captive Insurance Companies
PAST ARTICLES ON CAPTIVES
2020.03.25 ... The IRS Sends Soft Warning Letters To Thousands Of 831(b) Risk-Pooled Captive Owners
2020.02.04 ...The IRS Strikes A Rich Seam Of Tax And Penalty Gold In Risk-Pooled 831(b) Captives And Is Sending In More Miners
2019.12.31 ... The Next Generation Captive Insurance Tax Shelter Explained
2019.12.05 ... Bitter Coffee: Starbucks Squabbles With The Washington Insurance Commissioner Over $633 Million Paid To Its Captive Insurance Company
2019.11.17 ... IRS Suggests Criminal Referrals To Be Made In Abusive 831(b) Captive Tax Shelter Cases
2019.09.28 ... Johnson & Johnson Wins Appeal On $60 Million Tax Case To New Jersey For Captive Insurance Company
2019.09.26 ... Understanding The IRS Settlement Initiative Offer For Targeted 831(b) Captive Insurance Companies
2019.09.16 ... IRS Announces Global Settlement Of Abusive 831(b) Captive Insurance Tax Shelters
2019.08.08 ... Artex Defeats Attempt To Form Class Action And Forces Individual Arbitration Of Captive Disputes
2019.07.04 ... Second Class Action Against A Risk-Pooled 831(b) Captive Promoter Roils Sector
2019.05.28 ... New York Denies Stewart's Shops Deduction For Premiums Paid To Its Captive Insurance Company
2019.05.23 ... Sixth Circuit Also Gives CIC Services Thumbs-Down On IRS Notice 2016-66 Challenge
2019.04.23 ... Third US Tax Court Opinion Denies Deductions For Risk-Pooled 831(b) Captive Arrangement In Syzygy
2019.03.29 ... Macy’s Captive Insurance Company Faces Potential $23.8 Million In Maryland Corporate Tax Liability
2018.09.05 ... Whistleblower Yanks Back Rug To Expose Alleged Dirt Of Moody's Captive Insurance Company
2018.07.28 ... Johnson & Johnson Loses $60 Million Case To New Jersey For Captive Insurance Company
2018.06.25 ... Analysis Of The IRS's Big Win Against Risk-Pooled Small Captives In Reserve Mechanical [Hot]
2018.06.19 ... Capstone's PoolRe Fails To Provide Risk Distribution In Reserve Mechanical Captive Insurance Case [Hot]
2018.05.27 ... Washington State Goes After Microsoft's Captive For Unpaid Premium Taxes And Unauthorized Insurance
2017.11.17 ... Avrahamis' Motion For Reconsideration Rolls Snake-Eyes In U.S. Tax Court
2017.11.04 ... Court Pours Out Lawsuit By CIC Services, LLC, And Ryan, LLC, To Stop Notice 2016-66
2017.10.11 ... Risk-Pooled 831(b) Captive Insurance Companies And Bad Practices Take A Beating In Avrahami [Highly Recommended]
2017.09.30 ... Avrahamis' Captive Manager Apparently Calling It Quits After Decision
2017.08.21 ... IRS Notches Big Tax Court Win On 831(b) Captive Insurance In Avrahami Decision
2017.06.25 ... Beware The Insane New Offshore Insurance Company Deals Sold By Some 831(b) Captive Managers
2017.4.23 ... Last Gasp Attempt To Stop Notice 2016-66 Fails, May 1 Filing Deadline Approaches Quickly
2017.2.12 ... Belated Musings About IRS Notice 2016-66 And 831(b) Captive Insurance Companies
2016.12.31 ... IRS Extends Deadline For Compliance With Notice 2016-66 For 831(b) Captives To May 1, 2017
2016.11.16 ... A Detailed Analysis of IRS Notice 2016-66 re 831(b) Captives
2016.11.13 ... Pretrial Memoranda Filed In Wilson 831(b) Captive Case Display IRS Attacks and Taxpayer Responses
2016.11.08 ... IRS Notice 2016-66 Regarding 831(b) Captive Insurance Companies Interpreted In Common English
2016.11.1 ... IRS Categorizes Certain 831(b) Captive Insurance Companies As A "Transaction Of Interest"
2016.10.15 ... 831(b) Small Captive Insurance Company Owners Face January 1 Deadline To Fix Ownership Structure
2016.9.29 ... Not All Captive Insurance Risk Pools Are Created Equally
2016.3.3 … Happy 75th Birthday to Helvering v. Le Gierse
2015.12.19 ... Congress Makes 831(b) Captives Much Better And Deals With (Some) Abuses In 2015 Appropriations Bill
2015.12.8 ... 2015 Extender Bill May Throw Out 831(b) Captive Baby With The Bathwater
2015.11.29 ... The Sum Of All Fears About IRC 831(b) Tax Shelter Captives In Avrahami
2015.9.27 ... Residual Value Insurance Scores Big Win In U.S. Tax Court
2015.8.12 ... Donaldson And Crithfield Enter Guilty Pleas In Foster Dunhill Tax Fraud Case
2015.6.11 Treasury To Study Possible Abuses Of Small Captive Insurance Companies
2014.11.1 ... Securitas Secures Big Win For Captive Insurance In U.S. Tax Court
2014.9.18 ... IRS Launches Promoter Audits Of Captive Managers Suspected Of Abusive Practices
2014.4.20 ... Life Insurance and the 831(b) Captive Insurance Company – Wait For The Test Case Before Signing Up
2014.3.27 ... The IRS Discloses The 953(d) Trapdoor For Offshore Captives
2014.3.17 ... IRS Noose Starting To Tighten On Sham Risk Pools
2014.2.21 ... Rent-A-Center Creates A Captive Insurance Legacy In Tax Court
2013.11.16 ... Cell Captives And The Recycling Of Capital
2013.9.28 ... Manager Complaints Bubble To Surface Regarding Delaware Captive Insurance Companies
2013.9.21 ... IRS Filling The Pipeline With Captive Insurance Cases And Focusing On Dubious Practices
2013.8.10 ... Ten Favorite Things About Captive Insurance Companies
2013.7.28 ... Tax Shelters, Nebraska Hurricanes And Other Captive Insurance Mistakes
2013.6.23 ... Foster and Dunhill Scheme Ends In Denial Of Deductions And Indictments For Bogus Insurance Tax Shelter
2013.6.9 ... Texas Adopts Captive Insurance Legislation But Beware
2012.8.31 ... Broughton -- Rented Assets And Bogus Offshore Insurance Companies
2012.2.9 ... Sperl: Offshore Reinsurance Scheme And Other Tax Evasion Nets Accountant 36 Months
2011.9.24 ... 'Tis The Season For Tax Shelters, Fa La La La La And Grab Your Wallet
2020.03.25 ... The IRS Sends Soft Warning Letters To Thousands Of 831(b) Risk-Pooled Captive Owners
2020.02.04 ...The IRS Strikes A Rich Seam Of Tax And Penalty Gold In Risk-Pooled 831(b) Captives And Is Sending In More Miners
2019.12.31 ... The Next Generation Captive Insurance Tax Shelter Explained
2019.12.05 ... Bitter Coffee: Starbucks Squabbles With The Washington Insurance Commissioner Over $633 Million Paid To Its Captive Insurance Company
2019.11.17 ... IRS Suggests Criminal Referrals To Be Made In Abusive 831(b) Captive Tax Shelter Cases
2019.09.28 ... Johnson & Johnson Wins Appeal On $60 Million Tax Case To New Jersey For Captive Insurance Company
2019.09.26 ... Understanding The IRS Settlement Initiative Offer For Targeted 831(b) Captive Insurance Companies
General Resources
- Articles On Captives ... An archive of articles by Jay Adkisson on captive insurance companies
- Captive Insurance Litigation Issues ... Procedural and similar court issues involving captive insurance company arrangements that are in litigation.
State Regulation
- State Regulation Of Captives ... Issues related to the regulation and taxation of captives by the states
U.S. Tax Considerations For Captive Arrangements
- Captive Taxation Generally ... An overview of captive taxation, including the IRS's abandonment of its "Economic Family Theory"
- Protected Cell and Series Captives ... Considers the unique tax issues that involve protected cell companies (PCCs) and series business units (SBUs)
- Tax: Risk Distribution: Multiple Insureds ... Considers the IRS safe harbor for multiple insureds and risk distribution through many "points of insurance" generally
- Tax: Risk Distribution: Unrelated Insurance ... Describes the IRS "50% unrelated third-party insurance" safe harbor and related issues
- Tax: Risk Distribution: Risk Pools ... Introduces the concept of risk pools which are sometimes used by captive managers to assist their clients in obtaining 50% third-party insurance, and which are currently under heavy scrutiny by the IRS
- Tax: Risk Shifting ... Considers the tax law requirement that an insurance arrangement have a true shifting of risk between the insured and the insurer
§ 831(b) Captives
- 831(b) Captives Generally ... Discusses the unique characteristics and problems of captive insurance companies that qualify for the IRC section 831(b) election
- Class action lawsuits related to 831(b) risk-pooled captive tax shelters
Expert ... Expert witness and available for consultation as an expert regarding captive insurance company matters
Evaluation & Formation ... Jay has been involved with the formation of well over 100 captive insurance companies since 1998, and now assist prospective captive owners in evaluating their suitability for a captive, and in forming the captive and obtaining its insurance license
Litigation ... Frequently serves as counsel in disputes involving insurance companies
Remediation & Closing ... Remediation and termination of defective captive arrangements, and consulting and second-opinion reviews of existing captives
Follow Adkisson's Captive Insurance Companies on social media:
- Twitter feed on asset protection is found at: https://twitter.com/jay_adkisson
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- Jay Adkisson - More about Jay D. Adkisson, background, books, articles, speaking appearances.
- Asset Protection - The all-time best-selling book on asset protection planning by Jay Adkisson and Chris Riser.
- Collecting On A Judgment - An explanation of common creditor remedies, strategies and tactics to enforce a judgment, including a discussion of common debtor asset protection strategies.
- Voidable Transactions - Discussion of the Uniform Voidable Transactions Act (a/k/a 2014 Revision of the Uniform Fraudulent Transfers Act) and fraudulent transfer law in general.
- Private Retirement Plans - An exploration of a unique creditor exemption allowed under California law which can be very beneficial but is often misused.
- Charging Orders - The confusing remedy against a debtor's interest in an LLC or partnership is explained in reference to the Uniform Partnership Act, the Uniform Limited Partnership Act, and the Uniform Limited Liability Company Act.
- Protected Series LLCs - An examination of the single most complex statutory legal structure yet created, with particular reference to the Uniform Protected Series Act of 2017.
- California Enforcement of Judgments Law - Considers the topic of judgment enforcement in California, including the California Enforcement of Judgments Law and other laws related to California creditor-debtor issues.
- Anti-SLAPP Laws - A collection of and commentary about Anti-SLAPP laws and significant court decisions on the subject within the United States, and special section on California Anti-SLAPP laws.
Adkisson's Captive Insurance Companies (2006) available at Amazon.com
Contact Jay at by e-mail to jay [at] jayad.com or to 702-953-9617
© 2020 Jay D. Adkisson. All Rights Reserved. No claim to original government works. The information contained in this website is for general educational purposes only, does not constitute any legal advice or opinion, and should not be relied upon in relation to particular cases. Use this information at your own peril; it is no substitute for the legal advice or opinion of an attorney licensed to practice law in the appropriate jurisdiction. This site is https://captiveinsurancecompanies.com