Taxation
CIC Services Files Second Lawsuit Against IRS over Micro-Captive Rules
Captive manager CIC Services has filed a second lawsuit against the Internal Revenue Service (IRS) looking to invalidate an IRS rule targeting micro-captives. CIC Services says the rule is regulatory overreach by the IRS and that the new rule mirrors an earlier regulation that was struck down in court. Learn More
Tax Court Again Considers an IRC Section 831(b) Case and Rules in Favor of the Internal Revenue Service
The Tax Court in Genie R. Jones v. Comm’r ruled against a captive insurer electing 831(b) status, citing lack of risk distribution, non-arm's-length premiums, and failure to operate as a bona fide insurer. The decision continues a pattern of unfavorable rulings where captives lack key elements of valid insurance operations. Learn More
Oklahoma Insurance Department Revises Captive Premium Tax Forms Following Reporting Error
The Oklahoma Insurance Department revised its captive insurance premium tax forms after an error miscalculated the minimum tax due. Captive managers must delete draft filings and use the corrected National Association of Insurance Commissioners OPTins form. Updates clarify fiscal-year filings and prorated taxes for new captives. The March 1 filing deadline remains unchanged. Read More
The IRS's 831(b) Regulations: Industry Concerns and Legislative Responses
The 831(b) Institute advocates against the latest Internal Revenue Service (IRS) regulations on 831(b) captive insurance, arguing they impose unfair compliance burdens. This article examines industry concerns, key court rulings, and legislative efforts to protect captives as a risk management tool, providing insight into the advocacy efforts shaping the regulatory landscape. Read More
Fight, Flight, or Adapt: Approaches to New Micro-Captive Regulations
Rob Walling of Pinnacle explores how 831(b) captives are reacting to the IRS's new regulations. Some are fighting back, others are adapting their structures, and some are shifting away from the election. Despite regulatory challenges, captive insurance remains a powerful tool for businesses managing risk and financial stability. Read More
Breaking Down the IRS's Final Regulations on Micro-Captive Insurance Transactions
The Internal Revenue Service (IRS) finalized regulations on micro-captive insurance, revising criteria for listed transactions and transactions of interest. New disclosure rules affect 831(b) captives, with a 90-day compliance window. Exemptions apply for consumer coverage reinsurance, and a new process allows streamlined revocation of the 831(b) election under Rev. Proc. 2025–3. Read More
IRS Finalizes Micro-Captive Regulations
The Internal Revenue Service (IRS) and the Treasury Department issued final regulations on micro-captive insurance arrangements, marking an effort to refine the framework for identifying and reporting abusive practices. Read More