It’s been said that history repeats itself, and this certainly seems to be the case when the Internal Revenue Service challenges captive insurance companies.  After a stinging defeat in early 2014

A common myth in the captive insurance industry is that captives should be managed as much as possible like third party, commercial insurers.  Specifically, captives should look to the standards of third party, commercial insurers when making such decisions as

A common myth foisted upon small and mid-size business owners by self-proclaimed captive experts is “your business does not have enough risk to justify a captive insurance company.”  We often encounter this myth when meeting with prospective captive owners and their advisors whose cursory web search on captives has stumbled across high profile “experts” and […]

An age old battle has been waged over the past three to four centuries regarding the role government is to play in the economy and in its policies toward large and small businesses.  It’s always tempting for politicians and government officials to favor large corporations because their wealth and scale can make it easy for […]

Time and again, the I.R.S. has argued that captive insurance companies should be operated like or resemble the practices of commercial insurers.  This line of argument and its permutations have repeatedly been struck down by the U.S. Tax Court in cases between the Service and captive owners.  In fact, it was most recently shrugged off […]