Avrahami v. Commissioner was a significant captive tax law case handed down last August. While the case involved a small 831(b) captive, there are lessons to be learned from the decision for large captives as well, including that the captive must be run in a manner that meets commonly accepted notions of insurance with regards to claims handling. Allison & Mosby-Scott Risk Management can help analyze captive structures and provide advice around captive best practices, including helping clients understanding the significance of the Avrahami decision for large captives.
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