The IRS notches a big win against an 831(b) risk-pooled captive in Avrahami v. Commissioner, finding that the pooling arrangement used by the captive to obtain risk distribution was not "insurance" in the tax law sense.
from Forbes Real Time https://www.forbes.com/sites/jayadkisson/2017/10/11/risk-pooled-831b-captive-insurance-companies-and-bad-practices-take-a-beating-in-avrahami/
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