Captive Taxation 2015: The Year in Review

Elizabeth Erickson and Kristen Hazel, working with Tom Jones, wrote in this bylined article that “2015 was an exciting year for captive insurance taxation, bringing with it important guidance with respect to what is, and what is not, insurance for federal tax purposes.” The authors reviewed major court cases and Treasury rulings which provided important insights on risk distribution and how it affects insurance characterization.