By Sean King, JD, CPA, MAcc
Principal, CIC Services, LLC
This is part two of our series on the recent Reserve Mechanical tax court opinion that gave the IRS a much-needed win.
In part one of this series we discussed the impact of the Reserve Mechanical decision on risk distribution arrangements in general and on risk pools in particular. We distinguished our views on that subject from those of alarmist commentators, instead placing ourselves
Captive Insurance Times (CIT) recently published Sean King’s second article on the Reserve Mechanical Tax Court Case. CIT titled Sean’s article, “The Return Of The King.” Sean is an Attorney and CPA and is a Founding Principal of CIC Services, LLC.
CLICK HERE to read Sean’s article in CIT Issue 154. Sean’s article begins on page 24.
Uncertain regulatory changes, increased costs of care and restrictions in access to coverage continue to threaten the amount of control employers have over their healthcare insurance. Industry studies show that employee benefits can account for over 35% of payroll expenses and that the availability and quality of benefits programs are among the key determining factors in an employer’s ability to attract and retain talent. With the challenges of today’s business environment
After a decades long streak of losing most every Tax Court case of consequence involving captive insurance companies, the IRS has managed over the last year to win two, though they are both of questionable relevance to most of the captive insurance industry.
The most recent case is called Reserve Mechanical. Like Avrahami, it involved facts that are atypical to those of most of our clients, facts that