Court Concludes Tax Elections Invalid in Avrahami and Feedback Decision

August 22, 2017

On August 21, 2017, the US Tax Court decided two companion cases, Avrahami v. Commissioner and Feedback Insurance Company, Ltd., v. Commissioner, 149 T.C. No. 7, which involved issues around the formation and operation of a captive in Saint Kitts and elections under Internal Revenue Code sections 953(d) and 831(b). Read More

"Insurance Risk" Defined by IRS

March 7, 2016

Internal Revenue Service ruling specifies types of coverage that do not qualify as insurance risk for determining tax-deductibility of premiums paid to a captive insurer. Read More

US Tax Court: Securitas a Bona Fide Captive Insurance Arrangement

October 30, 2014

US companies are entitled to premium and interest expense deductions if a captive is created for business purposes, an opinion of the US Tax Court has determined. Read More