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Captive Insurance, Part I: An Overview

By Farrell Fritz P.C. on March 16, 2015
Posted in Federal Tax Issues

The IRS recently considered whether an arrangement between members of a corporate group and its affiliated insurance company, involving foreign currency fluctuations, constituted insurance for Federal tax purposes. For reasons that we will describe, the IRS concluded that the arrangement did not constitute insurance. captive

Before getting into the details of the IRS’s holding, however,…

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