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Protected Cell Captives - Rev.Ruling 2008-8

http://www.captiveinsurancecompanies.com/tax_rev-rul-2008-8.html

Revenue Ruling 2008-8 on Protected Cell Captives. RevRul.2008-8 provides guidance on the standards for determining whether an arrangement between a participant and cell of a Protected Cell Company (defined below) constitutes insurance for federal income tax purposes, and whether amounts paid to the cell are deductible as insurance premiums under 162 of the Internal Revenue Code. And Barnes and Noble. Section 162.- Trade or Business Expenses. 26 CFR 1.162-1: Business Expenses. (Also 801, 831). Neither the...

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Revenue Ruling 2005-40

http://www.captiveinsurancecompanies.com/tax_rev-rul-2005-40.html

IRS Rev. Rul. 2005-40. IRB 2005-27, 7/5/2005. Insurance, federal income tax purposes. This ruling considers four circumstances in which arrangements between unrelated entities do, and do not, constitute insurance for federal income tax purposes and whether the issuer qualifies as an insurance company for federal income tax purposes. Do the arrangements described below constitute insurance for federal income tax purposes? Neither the Code nor the regulations define the terms "insurance" or "insurance cont...

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Revenue Ruling 2002-90

http://www.captiveinsurancecompanies.com/tax_rev-rul-2002-90.html

2002-52 I.R.B. 985 (12/30/2002). Section 162. - Trade of Business Expenses. 26 CFR 1.162-1: Business Expenses. (Also sections 801, 831). Captive insurance. This ruling considers under which payments for professional liability coverage by a number of operating subsidiaries to an insurance subsidiary of a common parent constitute insurance for federal income tax purposes. Rev Rul. 2002-90. Neither the Code nor the regulations define the terms "insurance" or "insurance contract." The United States Supre...

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Adkisson's Captive Insurance

http://www.captiveinsurancecompanies.com/tax_stupid-captive-tricks.html

Didn't Get the News About 501(c)(15)? For whatever reasons, there still seem to be a few people who have not yet received the news the 501(c)(15) captive is effectively no more. While Congress did not abolish 501(c)(15) insurance companies outright, Congress instead created a $600,000 maximum limit for gross receipts of both the insurance company and other companies held by the same control group. The Sham Segregated-Cell Captive. At any rate, what happens is about the same in all these schemes: The phys...

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Revenue Ruling 2002-91

http://www.captiveinsurancecompanies.com/tax_rev-rul-2002-91.html

2002-52 I.R.B. 991 (12/30/2002). Section 831 - Tax on Insurance Companies other than Life Insurance Companies. 26 CFR 1.831-3: Tax on insurance companies (other than life or mutual), mutual marine insurance companies, mutual fire insurance companies issuing perpetual policies, and mutual fire or flood insurance companies operating on the basis of premium deposits; taxable years beginning after December 31, 1962. (Also sections 162, 801; 1.162-1, 1.801-3 .). Rev Rul. 2002-91. No Member owns more than 15% ...

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501(c)(15) Exempt Captives

http://www.captiveinsurancecompanies.com/captive_insurance_501c15.htm

501(c)(15) Exempt Insurance Companies. For whatever reasons, there still seem to be a few people who have not yet received the news the 501(c)(15) captive is effectively no more. While Congress did not abolish 501(c)(15) insurance companies outright, Congress instead created a $600,000 maximum limit for gross receipts of both the insurance company and other companies held by the same control group. 26 USC. section 501(c)(15). A) Insurance companies (as defined in section. Which are received during such y...

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Rent-A-Captive Arrangements and Segregated Portfolio Captives

http://www.captiveinsurancecompanies.com/type_rent-a-captive.htm

Protected Cell Companies and. IRS kills deductibility of premium payments made to most rent-a-captive arrangement and segregated portfolio company arrangements. Holding that each cell must meet the risk distribution requirements as if it were a stand-alone captive. Segregated portfolio companies usually try to set up many cells for many insureds, sometimes hundreds, and rake in large rent-a-captive fees. While convenient for the promoter and to a degree convenient for those renting the cells, the arr...

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IRS Rev. Rul. 2002-89

http://www.captiveinsurancecompanies.com/tax_rev-rul-2002-89.html

2002-52 I.R.B. 984 (12/30/2002). Section 162. - Trade or Business Expenses. 26 CFR 1.162-1: Business Expenses. Also sections 801, 831). Captive insurance. This ruling considers circumstances under which arrangements between a domestic parent corporation and its wholly owned insurance subsidiary constitute insurance for federal income tax purposes. Rev Rul. 2002-89. In implementing the arrangement, S may perform all necessary administrative tasks, or it may outsource those tasks at prevailing commercial m...

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831(b) Captive Insurance Company

http://www.captiveinsurancecompanies.com/captive_insurance_831b_election.htm

831(b) Captive Insurance Companies. An insurance company, including a captive, may elect under 28 U.S.C. sec. 831(b) to be taxed on its investment income only, so long as the company receives less than $1.2 million in premium each year. The 831(b) election is filed along with the company's first tax return, and cannot be revoked without the consent of the Secretary of the Treasury. 26 USC. sec. 831. B) Alternative tax for certain small companies. By the rates provided in section 11 (b). This subsection s...

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Workers Compensation Captive Insurance Companies

http://www.captiveinsurancecompanies.com/type_workers_compensation_captive.htm

Workers Compensation Insurance presents a special difficulty for captives, since they are usually not licensed to underwrite such insurance directly. This isn't true with workers compensation. If the captive doesn't pay, it is the worker who feels the hurt of not having insurance. Thus, the insurance commissioner will usually not allow a captive to offer workers compensation insurance unless the insurance company has a bunch of capital such as $10 million or more. The front company does not want to under...