How will “problematic” Greenbook proposals hurt 831(b) industry?

US lawmakers fire another arrow at the micro-captive sector, but how damaging...
MORE

US Treasury’s ‘Green Book’ proposes new 831(b) ownership rules

Treasury states “a statutory remedy” is needed to address “the pervasiveness of...
MORE

IRS scrutiny sees 56 Nevada 831(b) captives close in 2023

Nevada’s Division of Insurance estimates that of its 71 surrendered captive licences,...
MORE

Oklahoma reveals 2023 captive figures

Of Oklahoma’s 59 captives and cell/series captives, 16 of them took the...
MORE

Utah welcomes innovative new captives amid “chilling effect” of IRS scrutiny

While Utah captive director Travis Wegkamp says IRS scrutiny has had “chilling...
MORE

IRS wins sixth micro-captive court case

Tax Court’s opinion in Swift vs Commissioner found two St Kitts and...
MORE

What does latest IRS court victory mean for 831(b) captives?

Captive insurance tax experts speak to Captive Review about Keating vs Commissioner...
MORE

IRS wins latest 831(b) microcaptive court case

US Tax Court found Anguilla-based captive Risk Retention Ltd was not “insurance...
MORE

House Ways and Means Committee backs microcaptives in letter to IRS

The committee wrote to IRS commissioner Daniel Werfel giving their "strong support"...
MORE

Captive owner Q&A: David Findlay, Lake City Bank

The IRS’ proposals for identifying certain 831(b)-electing captives as ‘listed transactions’ have...
MORE

Community bank captive will “likely dissolve” under IRS’ 831(b) proposals

The owner of Lake City Bank’s captive tells Captive Review why the...
MORE

Half time report: signs of a captive growth slowdown as IRS scrutiny bites

Property is the main driver of captive growth in the first half...
MORE

Delaware H1 captive dissolutions almost entirely 831(b) companies

dollar dissolve
Other 831(b)-electing captives are choosing not to renew policies until the IRS...
MORE

IRS 831(b) micro-captive proposals: what to expect next?

In the wake of vehement opposition through a comments period and public...
MORE

Federal judge vacates IRS Notice 2016-66, calls it “arbitrary and capricious”

The Internal Revenue Service (IRS) has lost its bid to enforce its...
MORE

IRS targeting “abusive” microcaptives with 200 more attorneys

The Internal Revenue Service (IRS) has furthered its crackdown on "abusive" microcaptives...
MORE

Clark launches legal challenge over Avrahami penalties

The infamous Avrahami captive insurance case is back in court as the...
MORE

Microcaptives back on IRS Dirty Dozen list

The Internal Revenue Service (IRS) has once again featured microcaptives on its...
MORE

IRS targets microcaptive “promoters” with new investigations office

The Internal Revenue Service (IRS) has announced the establishment of the Office...
MORE

Are the IRS’s new captive insurance settlement terms worth it?

By Charlie Ruchelman and Ben Eisenstat Caplin and Drysdale The IRS does...
MORE

BREAKING: Microcaptive critic named assistant secretary for tax policy

Economist Mark J. Mazur has been named assistant secretary for tax policy...
MORE

Are the IRS settlement terms worth it?

By Charlie Ruchelman and Ben Eisenstat The IRS does not like Section...
MORE

IRS will consider “additional guidance” for micro captives

The Internal Revenue Service (IRS) has said it may consider additional guidance...
MORE

IRS expands captive enforcement

The Internal Revenue Service (IRS) has expanded its enforcement focus into "abusive"...
MORE

Artex class action dismissed by judge

An appeal from members of a class action suit filed against Artex,...
MORE

Captives: What you need to know this week

Welcome to another week in the captive world, and our new week...
MORE

US Senator asks Treasury to suspend IRS microcaptive investigation

United States Senator Cory Gardner has written to the US Treasury to...
MORE

‘Majority of microcaptive cases’ examined are abusive: IRS

The Internal Revenue Service (IRS) has stated that the "majority" microcaptive cases...
MORE

Judge rules in Arsenal-Jade Risk case

A judge has ruled in favour of the former owner of Jade...
MORE

IRS sends more letters to micro captives

The United States Internal Revenue Service (IRS) has sent another batch of...
MORE

EXCLUSIVE: Captive organisations file brief for IRS Supreme Court case

EXCLUSIVE: Almost two dozen captive organisations will today file a brief with...
MORE

Micro captives removed from IRS ‘Dirty Dozen’ list

The United States Internal Revenue Service (IRS) has unveiled its "dirty dozen"...
MORE

EXCLUSIVE: IRS takes Delaware Department of Insurance to court

The US Internal Revenue Service (IRS) has taken the Delaware Department of...
MORE

Supreme Court to hear CIC Services IRS case

The United States Supreme Court has agreed to hear CIC Services' case...
MORE

Covid-19, the IRS and captives

By Nate Reznicek We find ourselves in an interesting time. The threat...
MORE

IRS “insensitive and draconian” over micro captive letters

The Self-Insurance Institute of America (SIIA) has written to the Internal Revenue...
MORE

Coronavirus shows IRS was wrong about microcaptives

The coronavirus pandemic has shown how the Internal Revenue Service (IRS) and...
MORE

Micro captives, mega issues

Last month, the Internal Revenue Service (IRS) announced that it has established...
MORE

US news attacks captives and links to Bernie Sanders

Last Wednesday US news website The Daily Beast described captive insurance companies...
MORE

IRS settlement details revealed

Captives that have been offered a settlement by the Internal Revenue Service...
MORE

IRS settlement offer a ‘non-event’, says Oxford RMG

The Internal Revenue Service’s (IRS) settlement offer is a non-event in the...
MORE

Captives under audit offered IRS settlement

The Internal Revenue Service (IRS) has offered 200 captives currently under audit...
MORE

Exclusive: 831(b) lawsuit defendants leave Artex

Three Artex employees have left the company, Captive Review can reveal. Jeremy...
MORE

831(b)’s a ‘legit risk management mechanism’, says captive owner

Captive insurance companies electing to operate under the 831(b) tax rules have...
MORE

Artex motion to dismiss ‘civil conspiracy’ suit granted

Artex’s joint motion to dismiss a class action suit alleging it promoted...
MORE

North Carolina licences five new captives

North Carolina has licensed five new captives so far this year, filings...
MORE

Avrahami’s complain of ‘flawed insurance product’ in latest class action suit

The Avrahami’s and their captive Feedback Insurance Company have filed a class...
MORE

CIC denied injunction on Notice 2016-66

Tennessee-based captive manager CIC Services has been denied an injunction delay on...
MORE

Q&A: Captive Alternatives’ David Kirkup on Syzygy

Last month, Captive Review reported that the US Tax Court had ruled...
MORE

Whitehouse: Case for 831(b)s is improving

The case for 831(b) captives is improving despite the latest Internal Revenue...
MORE

IRS prevails in Syzygy 831(b) case

The US Tax Court has ruled in favour of the Internal Revenue...
MORE

Frontrunner Captive Management: Captives must ‘re-inspect their defences’

It is time for captives to “re-inspect their defences”, as the IRS...
MORE

Tennessee captive market performing at ‘healthy rate’

The captive insurance industry in Tennessee has performed at a “very healthy...
MORE

Artex, Gallagher case could ‘taint the industry’

The class action lawsuit against a group including Artex and Arthur J...
MORE

831(b) lawsuits ‘like school of piranhas’ – Jay Adkisson

Class action lawsuits against captives found to not be in compliance with...
MORE

Artex, Arthur J Gallagher among group accused of 831 (b) captive ‘conspiracy’

A group of plaintiffs have filed a class action lawsuit against a...
MORE

831(b) limit to remain unchanged for 2019

The limit on annual premium written by captives wishing to make the...
MORE

Risk Strategies “comfortable” with 831(b) association after Oxford acquisition

Mike Christian, founder and CEO of Risk Strategies, has told Captive Review...
MORE

US Tax Court: A Pipeline of Small Captive Cases

Charles Lavelle, senior partner at Bingham Greenebaum Doll LLP, provides Captive Review...
MORE

Avrahami to become go-to guide for Tax Court cases concerning small captives

In light of Judge Kathleen Kerrigan’s continued citing of Avrahami in her...
MORE

Reserve Mechanical has “stronger fact patterns than Avrahami”, but outcome “not shocking”

Tax and captive insurance professionals have provided their initial reaction to the...
MORE

Avrahami had a “chilling effect” on US captive industry – Steve Kinion

A combination of the Avrahami ruling and the PATH Act led to...
MORE

Small captives in transition and growth is slowing – Brady Young

The growth in America’s smaller captive numbers may be slowing down, but...
MORE

PATH Act clarifications included in Congress’ federal spending bill

Three key areas of the Protecting Americans from Tax Hikes Act of...
MORE

831(b) captives remain on IRS’ ‘Dirty Dozen’ list

Captive insurance companies making the 831(b) tax election will remain under heavy...
MORE

CICA restructures small captives task force

The Captive Insurance Companies Association (CICA) has updated its Small Captives Task...
MORE

Practical Concerns for 831(b) Captive Owners Post Avrahami

Captive owners making the 831(b) tax election are reassessing their structures and...
MORE

First inflation adjustment triggered for 831(b)s

The first adjustment to the premium limit for 831(b) electing captives in...
MORE

831(b) owners seeking second opinion on structures

Businesses that own 831(b) captives are contacting captive managers and other third-party...
MORE

Celia Clark responds to latest Avrahami motion

The Avrahamis lost its bid for two motions of reconsideration in November...
MORE

Judge Holmes criticises “sloppy” policy language in latest Avrahami exchange

The Avrahami’s move for reconsideration of two findings of fact has been...
MORE

Lessons Learned from Avrahami

Peter Johnson, senior actuarial consultant and property & casualty practice lead at Spring...
MORE

Connecticut keen to “revive” 831(b) reputation – Michael Maglaras

Michael Maglaras, chairman of the Connecticut Captive Insurance Association, believes it is...
MORE

CIC Services considering options after Notice 2016-66 defeat

CIC Services and Ryan, LLC have had their case against the Internal...
MORE

Exclusive: Celia Clark responds to Avrahami criticism

Celia Clark, the captive manager of Feedback Insurance Company and a former...
MORE

The Avrahami Record, by Celia Clark

Captive Review has reported extensively on the Avrahami v Commissioner case, including...
MORE

Avrahami manager to close captive practice

Clark & Gentry, PLLC, the firm responsible for structuring and managing the...
MORE

Avrahami – The Wider Implications

What does the future hold for larger captives in the post-Avrahami-decision world? ...
MORE

ABA appoints John Dies to captive committee

John Dies, alliantgroup’s managing director of tax controversy, has joined the American...
MORE

Capstone weighs in on Avrahami decision

Texas-based Capstone Associated has published an extensive critique of the Avrahami captive...
MORE

Exclusive: Avrahami actuary responds to US Tax Court criticism

The actuary that priced the premium for Feedback Insurance Company, the captive...
MORE

AVRAHAMI v. COMMISSIONER – The Details

Charles J. Lavelle, Brett J. Miller and Ross D. Cohen, of Bingham...
MORE

Final Word: How should a captive price terrorism?

Tammi Brown and Doug Butler, of MIJS, discuss terrorism as an insurable...
MORE

AVRAHAMI: Opinion will embolden the IRS, settlements more expensive

The Internal Revenue Service will be “emboldened” by their win in the...
MORE

AVRAHAMI: Industry distances itself from “negative facts”

Industry players have expressed little surprise at the outcome of the Avrahami...
MORE

AVRAHAMI: Tax Court slams promoter, premiums “utterly unreasonable”

The United States Tax Court has lambasted the promoter who sold and...
MORE

AVRAHAMI: Premium NOT insurance, 831(b) election invalid – US Tax Court

The United States Tax Court has ruled in favour of the Internal...
MORE

Treasury snubs Notice 2016-66 in interim report

Notice 2016-66 has not been included on the Treasury’s interim list of...
MORE

Request to include Notice 2016-66 in Trump report

The Self-Insurance Institute of America (SIIA) has written to the Treasury requesting...
MORE

13 states requesting Form 8886 filings from 831(b) captives

Captive managers and material advisors to captives making the 831(b) tax election...
MORE

Captives Receive Great News, IRS loses on Substance over Form

Richard M. Colombik, of TLS Marketing and Management Services, LLC , and Jeremy P....
MORE

Citadel Risk launches Tennessee cell company, targets 831(b) business

A new incorporated cell company has been formed in Tennessee by Citadel...
MORE

Notice 2016-66 injunction denied

An attempt to get a preliminary injunction against the 1 May deadline...
MORE

Common Ground With The IRS?

The captive industry has reacted with scorn to the IRS’ attitude towards...
MORE

IRS is not acting in good faith – Sean King

Sean King, the captive manager behind a lawsuit seeking to postpone and...
MORE

CIC Services files second lawsuit against IRS

CIC Services has been joined by Ryan, LLC in filing a lawsuit...
MORE

Federal district court upholds attorney-client privilege claim

The federal district court has agreed with the original decision of the...
MORE

The possible ramifications of Notice 2016-66 on the Path Act

Jeremy Colombik is president of Management Services International (MSI). MSI currently manages...
MORE

Connecticut commissioner set to investigate microcaptives

Connecticut’s insurance commissioner is set to embark on a study of those...
MORE

IRS keeps pressure on 831(b) with ‘Dirty Dozen’ return

The Internal Revenue Service has published its annual Dirty Dozen list of...
MORE

Exclusive: MIJS court victory against IRS a ‘game changer’ in 831(b) fight

A Summons issued by the Internal Revenue Service (IRS) to Moore Ingram...
MORE

Technical corrections to PATH Act expected in Congress

The United States’ smaller captive industry is optimistic that groundwork laid with...
MORE

SIIA asks IRS to suspend Notice 2016-66, cites Trump administration

The Self-Insurance Institute of America (SIIA) has criticised the “paperwork intensive approach”...
MORE

Vermont makes play for smaller captives with new legislation

The Vermont Captive Insurance Association (VCIA) has put forward a captive bill...
MORE

Uncertainty to remain and scrutiny to increase on 831(b)s – Jason Flaxbeard

Jason Flaxbeard, captive practice leader at Beecher Carlson, does not believe 2017...
MORE

Revealed: The 2016 Captive Review ERC Pioneers

Captive Review has published the second Enterprise Risk Captive (ERC) Pioneers list,...
MORE

CIC Services drops IRS lawsuit after Notice 2016-66 extension

CIC Services, LLC has dropped the lawsuit it filed against the United...
MORE

IRS extends Notice 2016-66 deadline by 90 days

Captive managers and material advisors working with captives making the 831(b) tax...
MORE

News Analysis: Tax Opinion Analyses 831(b) Options

A leading tax attorney has published three tax opinions discussing Notice 2016-66...
MORE

Tax opinion analyses 831(b) acquisition options

Owners of captives making the 831(b) tax election and wanting to get...
MORE

Colorado Senator first to lobby IRS over “burdensome” Notice 2016-66

A Democratic senator from Colorado has written to the Commissioner of the...
MORE

SIIA to request 831(b) reporting extension, Tarter bullish over new formations

The Self-Insurance Institute of America (SIIA) will write to the Internal Revenue...
MORE

IRS includes DoL exemption in 831(b) notice

Captive insurance companies that make the 831(b) tax election, but have successfully...
MORE

Industry slams ‘deliberately bad timing’ of IRS’ latest 831(b) Notice

The Internal Revenue Service (IRS) intentionally waited until the busy season to...
MORE

IRS gives captives three months to report, throws fuel on 831(b) fire

The United States Department of the Treasury and the Internal Revenue Service...
MORE

Premium increases on backburner as owners seek 831(b) compliance

Managers and captive owners using the 831(b) tax election are prioritising business...
MORE

SIIA and 15 captive associations lobby for Federal guidance on 831(b) rules

The Self-Insurance Institute of America (SIIA), along with 15 state captive insurance...
MORE

Delaware outlines streamlined application process for 831(b) compliance

The Delaware Department of Insurance has issued a bulletin detailing two procedures...
MORE

Avrahami ruling may be delayed until mid-2017

America’s captive insurance industry will have to keep waiting for further clarity...
MORE

831(b) rise to $2.2m peaking risk managers’ interest – JLT Towner

The 831(b) tax election, cell captives and solutions for the middle market...
MORE

Capstone adds lawyer to support 831(b) restructurings

The Feldman Law Firm LLP, the affiliated law firm of Houston-based captive...
MORE

IRS losing Avrahami could create open season for 831(b)s – Gary Osborne

Gary Osborne, president of USA Risk Group, believes the Internal Revenue Service...
MORE

Why is ERC good for you?

Enterprise risk captives, or ERCs, are booming business in the United States, but...
MORE

Puerto Rico expecting dramatic growth in micro-captives

David Kirkup, COO and CFO of insurance manager Captive Alternatives, has told...
MORE

Captive Review August Edition

What do Dennis Harwick, David Cameron and Gordon Rowell have in common?...
MORE

Premium increase is validation of micro-captive industry – Les Boughner

Les Boughner, chairman of Advantage Insurance Holdings’ business insurance division, believes changes...
MORE

831(b) re-structuring activity will take place in final months of 2016 – Steve Kinion

Steve Kinion, Delaware’s captive regulator, has told Captive Review he is expecting...
MORE

US Tax Court sides with IRS in pending micro-captive case

The Internal Revenue Service (IRS) has won an early victory in its...
MORE

Investors circling to purchase unwanted 831(b) captives

A new market for the acquisition of 831(b) tax electing captives has...
MORE

Dirty Dozen Captives: Rule or Exception?

Ryan Work is vice president of government affairs for the Self-Insurance Institute...
MORE

Micro captives keep their place on the IRS “Dirty Dozen” list

The United States’ Internal Revenue Service has placed captive insurance on its...
MORE

Changes to 831(b) – What now?

The 831(b) tax election for small captives continues to fill column inches....
MORE

Small captives have a shorter life span – David Snowball

Utah’s captive insurance regulator, David Snowball, has told Captive Review the majority...
MORE

The States’ Role in Regulating Small Captives

Small captives are rarely out of the headlines and under intense scrutiny...
MORE

Industry schism is losing the IRS fight over small captives – Jay Adkisson

The lack of unity within the United States’ captive insurance industry has...
MORE

Some smaller captives will have to restructure or close – regulators

A number of smaller captives making the 831(b) tax election will have...
MORE

Revealed: The 2015 Captive Review ERC Pioneers

The first Enterprise Risk Captive (ERC) Pioneers list has been published by...
MORE

Small modifications made to 831(b) legislation, sent to House

The tax extender package including significant changes to the 831(b) tax election...
MORE

831(b) uncertainty not impacting formation numbers

Captive managers and state regulators remain upbeat in the face of continued...
MORE

Industry rallying to fight “harmful” 831(b) legislation

America’s captive insurance industry, led by the Self Insurance Institute of America...
MORE

SIIA writes to captive regulators to share 831(b) legislation concerns

The Self-Insurance Institute of America (SIIA) has written to state captive insurance...
MORE

Signal Hill Petroleum 831(b) captives petition against IRS tax deficiency notice

Two Utah-domiciled captives making the 831(b) tax election have petitioned the Internal...
MORE

“Dirty Dozen” label should be a wake-up call – Dana Sheridan

Enterprise risk captives place on the Internal Revenue Service’s “Dirty Dozen” list...
MORE

Clear guidance needed for 831(b) service providers – Mike DiMayo

Mike DiMayo, principal at Oxford Risk Management Group, has called on the...
MORE

CICA updates 831(b) guidance

The Captive Insurance Companies Association (CICA) has published an “information statement” in...
MORE

831(b) family clampdown will surprise industry – Charles Lavelle

The Joint Committee on Taxation has proposed a complete ban on the...
MORE

Captive Review June Edition

A re-occurring battle for risk and insurance managers can often be justifying...
MORE

Legislation introduced to increase 831(b) premium allowance

The United States’ House of Representatives and Senate have received legislation that...
MORE

We will weigh in on 831(b) debate to avoid broad brush approach – Dennis Harwick

Dennis Harwick, president of the Captive Insurance Companies Association (CICA), believes it...
MORE

The Debate: 831(b) Tax Election

On no topic is the American captive insurance industry more divided than the...
MORE

Senate Finance Committee waters down 831(b) modification proposal

The United States’ Senate Finance Committee has dropped two proposed restrictions on...
MORE

Our captives are insurance companies, regardless of IRS statements – North Carolina

The North Carolina Department of Insurance has insisted its own internal scrutiny...
MORE

831(b) captives labelled a “charade” by IRS and adds to “Dirty Dozen” hit list

The United States’ Internal Revenue Service (IRS) has fired its latest warning...
MORE

We’d support a Europe equivalent to the 831(b) – Willis

Senior figures at Willis Global Captive Practice have told Captive Review they...
MORE

Enterprise Risk Captive Report 2015

Captive Review’s first Enterprise Risk Captive Report analyses the key issues surrounding the...
MORE

Make sure 831(b) captives are true insurance vehicles – Smith

Rich Smith, president of the Vermont Captive Insurance Association (VCIA), has called...
MORE

Feldman extends legal services to third-party managed captives

The affiliate law firm of Capstone Associated Services is to begin working...
MORE

EU domiciles should offer an equivalent to the US 831(b) – Urs Neukomm

Urs Neukomm, director of strategic solutions for corporates at Swiss Re, has...
MORE

News Feature: American inspiration for Europe’s mid-market?

As the US captive industry profits from the rapid growth in mid-market...
MORE

Bahamas forecast as next hub for 831(b)’s

The Bahamas is forecast to be the next major domiciles for 831(b)...
MORE

PCC’s more flexible than 831(b) micro captives

Protected cell captives (PCC) are an attractive alternative for smaller parent companies,...
MORE

Bahamas 'risen from extinction' in captive market

US-based The Strauss Law Firm LLC said the Bahamas has "risen from...
MORE
Dale Sagen, vice-president and business development leader with QBE Accident & Health, on how captive...
MORE
Captive Review has featured hundreds of prevalent captive leaders over our 25 years of existence,...
MORE
As Captive Review celebrates its 25th year in 2024, outgoing Captive Review publisher Nick Morgan...
MORE
As Captive Review turns 25 this year, leaders from the industry share their thoughts on...
MORE