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Expert Analysis

What To Know About IRS Microcaptive Insurance Settlements

By Philip Karter ( February 10, 2020, 5:14 PM EST) -- As taxpayers participating in microcaptive insurance arrangements are well aware, on the heels of three victories in the three captive decisions issued by the U.S. Tax Court — Avrahami v. Commissioner[1], Reserve Mechanical Corp. v. Commissioner,[2] and Syzygy Insurance Co. Inc. v. Commissioner,[3] — the Internal Revenue Service has increasingly approached Internal Revenue Code Section 831(b)[4] captive audits with a take-no-prisoners attitude....

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