"What The Insurance Industry Should Know About the IRS’s Campaign Against 'Abusive' Micro Captives"

[Editor’s note: This article reflects the views of the authors, and does not constitute legal or other professional advice or service by Carlton Fields Jorden Burt, PA and/or any of its attorneys. Richard D. Euliss is an attorney and Whitney A. Fore is a law clerk in the Washington, D.C. office of Carlton Fields Jorden Burt, P.A. A version of this article was published in issue 72 of Captive Insurance Times, http://captiveinsurancetimes.com/citimes/CITimes_issue_72.pdf and on www.ReinsuranceFocus.com.]

I. Introduction

Though in the midst of a stifling budget and personnel reduction, the United States Internal Revenue Service (“IRS”) recently announced an increased effort …