831(b) Diversification Requirements Far Less Daunting Than They Seem
As we noted last week, Congress created quite a stir in the captive insurance industry in mid-December of 2015 when it passed and President Obama signed a so-called “Tax Extenders” bill titled H.R. 34. This new legislation included Section 262 titled, “MODIFICATIONS TO ALTERNATIVE TAX FOR CERTAIN SMALL INSURANCE COMPANIES.” These modifications impact small captive insurance companies (CICs) that make an 831(b) tax election.
The legislation’s “diversification requirements” have created quite a stir with some industry pundits and domicile regulators suggesting many existing captives will have to restructure or close. We believe such allegations are