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NOT SO INDEPENDENT CAYLOR – THE NEWEST RULING ON “MICRO-CAPTIVES” FROM THE IRS

On Wednesday, March 10, the Tax Court issued its fourth case concerning “Microcaptive” insurance companies. In Caylor Land & Dev. v. Comm’r, the IRS continues its winning streak against captive arrangements. In the words of Judge Holmes, who authored the opinion as well as that of the seminal Avrahami case, “We will break no new…

California FTB Begins looking at Captive Insurance Companies

While states often lag behind the IRS in enforcement of IRS priority issues, the California Franchise Tax Board (FTB) has begun to show an interest in looking deeper into captives owned by California residents. While the FTB has made no formal pronouncements about its intention (unlike the IRS, which has classified certain microcaptive transactions as…

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