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…