Captive Insurance companies, are sometimes used to purchase life insurance outside the estate of the business owner with what amounts to pre-tax dollars. This should not be the primary focus of the captive, but is something that can be done with a portion of the captive's accumulated assets. If the primary purpose of the captive is to buy life insurance, or act as the conduit for the pre-tax purchase for life insurance, or if life insurance becomes the significant asset of the captive, there is a risk that the arrangement will not be considered a bona fide captive arrangement but will instead be treated as a tax shelter. A captive is an insurance company, and should be treated as such, not a vehicle for investing.
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Litigation Consulting Case Evaluation Evidence Review and Forensic Analysis Research and analysis of tax and insurance laws Complaint, Petition, and Response Preparation Expert Witness Testimony Damage Calculations Expert Declarations and Affidavits Exhibits for Settlement Conference, Mediation, and Trial Active Litigation: Rebuttal Witness Deposition, Arbitration and Trial Testimony Plan reviews, evaluations and remediation And more, as needed
an expert can make a difference with any captive insurance problem HOW TO FIND THE RIGHT EXPERT TO GUIDE YOU THROUGH THESE TIMES vidual taxpayers and promoters, designated certain abusive life insurance arrangements as listed transactions, and imposed accuracy-related taxpayer penalties.
Happy New Year Mr. Wallach and thanks for the article
Ronald R. Itzkowitz National EP Customer Partnership Analyst Internal Revenue Service - Employee Plans
"Mr. Wallach, thanks so much for taking the time to talk to me today about VEBAs. Any information you can send me would be helpful. Hopefully, we can work together in the future as interest in VEBAs increase."
Corman G. Franklin Office of the Assistant Secretary for Policy U.S. Department of Labor G
ReplyDeleteUNDERSTANDING CAPTIVE INSURANCE
Captive Insurance companies, are sometimes used to purchase life insurance outside the estate of the business owner with what amounts to pre-tax dollars.
This should not be the primary focus of the captive, but is something that can be done with a portion of the captive's accumulated assets. If the primary purpose of the captive is to buy life insurance, or act as the conduit for the pre-tax purchase for life insurance, or if life insurance becomes the significant asset of the captive, there is a risk that the arrangement will not be considered a bona fide captive arrangement but will instead be treated as a tax shelter.
A captive is an insurance company, and should be treated as such, not a vehicle for investing.
Our Services
How we can help
Litigation Consulting
Case Evaluation
Evidence Review and Forensic Analysis
Research and analysis of tax and insurance laws
Complaint, Petition, and Response Preparation
Expert Witness Testimony
Damage Calculations
Expert Declarations and Affidavits
Exhibits for Settlement Conference, Mediation, and Trial
Active Litigation: Rebuttal Witness
Deposition, Arbitration and Trial Testimony
Plan reviews, evaluations and remediation
And more, as needed
an expert can make a difference with any captive insurance problem
HOW TO FIND THE RIGHT EXPERT TO GUIDE YOU THROUGH THESE TIMES
vidual taxpayers and promoters, designated certain abusive life insurance arrangements as listed transactions, and imposed accuracy-related taxpayer penalties.
ReplyDeleteHappy New Year Mr. Wallach and thanks for
the article
Ronald R. Itzkowitz
National EP Customer Partnership Analyst
Internal Revenue Service - Employee Plans
"Mr. Wallach, thanks so much for taking the time to talk to me today about VEBAs. Any information you can
send me would be helpful. Hopefully, we can work together in the future as interest in VEBAs increase."
Corman G. Franklin Office of the Assistant Secretary for Policy U.S. Department of Labor
G
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