The recent memorandum decision in Kadau v. Commissioner (T.C. Memo. 2025-81) provides a clear example of how the Tax Court currently analyzes micro-captive arrangements. Importantly, the opinion does not create new law; rather, it applies the well-established captive-insurance framework developed in Avrahami, Reserve Mechanical, Caylor, and Syzygy. We have previously distinguished how our clients do […]