Tax Opinions On Captive Insurance
831(b) RISK-POOLED CAPTIVE INSURANCE TAX SHELTERS COURT OPINIONS
Avrahami v. Comm'r, 149 T.C. No. 7 (Aug. 21, 2017).
Reserve Mechanical Corp. v. Comm'r, T.C. Memo. 2018-86, 2018 WL 3046596, T.C.M. (RIA) 2018-086, 2018 RIA TC Memo 2018-086 (June 18, 2018).
Syzygy Ins. Co. v. Comm'r, T.C. Memo. 2019-34 (April 10, 2019).
RECENT ARTICLES
2020.06.24 ... The U.S. Department Of Justice Files Suit To Enforce An IRS Summons Against The Delaware Department Of Insurance For Artex Transactions
2020.05.19 ... Coronavirus Pandemic Threatens Run On Business Interruption Policies Sold By Captive Insurance Risk Pools
2020.04.17 ... Coronavirus Pandemic Will Not Slow Down IRS’s Pursuit Of Microcaptive And Syndicated Conservation Easement Transactions Says LB&I Memo
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
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TOPICS
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
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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
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MORE INFORMATIONAL WEBSITES BY JAY ADKISSON
- Jay Adkisson - More about Jay D. Adkisson, background, books, articles, speaking appearances.
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- Creditor-Debtor Law - 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