-:ALL Credits Goes To Respective Creators :-
I have previously written about the IRS’s win against so-called “microcaptive” transactions in the Reserve Mechanical case, with a detailed explanation of the U.S. Tax Court’s opinion in that case in my article: Analysis Of The IRS’s Big Win Against Risk-Pooled Small Captives In Reserve Mechanical (June 25, 2018). That Tax Court decision was later appealed to the U.S. Court of Appeals for the Tenth Circuit, which finally issued its ruling on May 13, 2022, that you can read for yourself in full here.
Suffice it to say that the Reserve Mechanical case attracted a lot of attention within the small captive insurance sector. Numerous state captive insurance groups supported the captive insurance company in the appeal as amici curiae (albeit I found their brief to be very pedestrian, if not at points just plain awful, and the Tenth Circuit apparently didn’t make much of it either). This support for the taxpayer in the case indicated that pretty much the very existence of the risk-pooled small captive insurance industry teetered on the outcome of this case: If the IRS lost and the captive won, perhaps microcaptive transactions could survive after all. If the captive lost and the IRS won, it was all over for risk-pooled small captives.
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