IRS Repulsed In Rent-A-Center Captive Case – Additional Perspective
Last week, we noted that the Internal Revenue Service suffered another defeat on January 14, 2014 as the U.S. Tax Court handed down its ruling which upheld that payments by Rent-A-Center to its Bermuda-domiciled captive insurance company, Legacy Insurance Co. Ltd., were deductible as an insurance expense.
This ruling is particularly informative to captive owners and captive managers as Rent-A-Center and its captive insurance company, Legacy, employed some practices that many in the industry have traditionally regarded as “aggressive.” In losing this case, the I.R.S. (The Service) “lost some ground” in a manner of speaking.