{"title":"The Captive Insurance Timeline: The Tide Turns for Taxpayers","authors":"F. H. Stewart, Beckett G. Cantley","doi":"10.2139/ssrn.3858878","DOIUrl":null,"url":null,"abstract":"After several courts held for the IRS in captive insurance cases and denied the deductibility of premium payments, taxpayers started winning. This article discusses how those taxpayer victories validated captive insurance arrangements and showed that a diverse corporate structure could prevent application of the IRS's balance sheet theory.","PeriodicalId":186327,"journal":{"name":"FinPlanRN: Tax Reduction (Topic)","volume":"40 1","pages":"0"},"PeriodicalIF":0.0000,"publicationDate":"2015-05-19","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":"0","resultStr":null,"platform":"Semanticscholar","paperid":null,"PeriodicalName":"FinPlanRN: Tax Reduction (Topic)","FirstCategoryId":"1085","ListUrlMain":"https://doi.org/10.2139/ssrn.3858878","RegionNum":0,"RegionCategory":null,"ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":null,"EPubDate":"","PubModel":"","JCR":"","JCRName":"","Score":null,"Total":0}
引用次数: 0
Abstract
After several courts held for the IRS in captive insurance cases and denied the deductibility of premium payments, taxpayers started winning. This article discusses how those taxpayer victories validated captive insurance arrangements and showed that a diverse corporate structure could prevent application of the IRS's balance sheet theory.