Deliver to: Notice.comments@irscounsel.treas.gov
Introduction
Via IRS Notice 2016-66 (the “Notice”), the Internal Revenue Service (“IRS” or “the Service”) has invited the public to comment regarding how the Service might, via future guidance, articulate a principled distinction between abusive and legitimate captive insurance arrangements taxed under Section 831(b) of the Internal Revenue Code (“Microcaptives”).
I am an attorney and CPA. I have a Master’s Degree in Accounting with a concentration in taxation. I have been a licensed insurance broker actively working in the insurance industry for more than a quarter century. I have been heavily involved with managing captive insurance companies, often of the Microcaptive variety, for more than a decade. I have various securities licenses, and I am an investment advisor fiduciary to over $10 billion in qualified retirement plan assets. Given my background in accounting, law, taxation, insurance and investments, I believe that I’m uniquely qualified