The North Carolina Captive Insurance Association (NCCIA) is one of a number of state captive insurance associations protesting recent Internal Revenue Service (IRS) activities aimed at micro-captives. The NCCIA wrote North Carolina's congressional delegation for help in securing relief from a letter the IRS sent in March to micro-captive owners.
Wilson v. Comm'r, Docket 26547-13 (Tax Court) was quietly settled at the end of February.Â The case had been in the Tax Court for some time, and after Avrahami was decided, supplemental briefs were requested by the court. The facts of the case are very similar to Avrahami.
A group of captive insurance associations filed a friend of the court brief supporting Reserve Mechanical Corp.'s appeal of a US Tax Court insurance tax case. The group expressed concern about areas of the Tax Court's ruling concerning prior loss history, standardized versus manuscripted policies, and risk pooling.
Reserve Mechanical Corp.'s first appeals brief outlines ways it says the US Tax Court erred in ruling against it in a captive insurance tax case, arguing that the captive insurance arrangement met necessary criteria for insurance.