IRC 831(b) Micro-Captives: Avoiding IRS Scrutiny, Diversification Requirements, Effective Transaction Structures
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE course will provide tax counsel and advisers with practical tools and guidance to ensure that clients utilizing micro-captive insurance companies are fully compliant with IRC Section 831(b) rules to preserve legitimate tax deduction of premiums. The panel will discuss tax benefits and compliance burdens to micro-captives and offer detailed guidance on structuring micro-captives to be fully compliant with Section 831(b) requirements.
Outline
- Recent cases and proposed regulations
- Anti-avoidance law
- Substance over form
- Business purpose
- Economic substance
- IRS broad enforcement capabilities
Benefits
The panel will review these and other important questions:
- Risk shifting and distribution
- IRS enforcement areas in micro-captives, including excessive premiums and risk definition
- 831(b) structuring issues and compliance challenges
- Diversification requirements and tests
- Response to IRS challenges of 831(b) micro-captive structures
Faculty
Alan J. Fine, CPA, JD
Tax Partner
Armanino
Mr. Fine specializes in the taxation of insurance companies. He has 24 years of tax experience and has worked closely... | Read More
Mr. Fine specializes in the taxation of insurance companies. He has 24 years of tax experience and has worked closely with insurance companies for 22 years. Prior to joining Brown Smith Wallace, Mr. Fine was a senior manager with a national accounting firm. He is responsible for serving insurers writing fidelity, personal and commercial lines; medical and life insurance; other professional malpractice coverages; and captive insurance companies.
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Kevin Oveisi
Attorney
Holtz, Slavett & Drabkin
Mr. Oveisi is a tax attorney with Holtz, Slavett, & Drabkin. Kevin has experience practicing in all aspects of tax... | Read More
Mr. Oveisi is a tax attorney with Holtz, Slavett, & Drabkin. Kevin has experience practicing in all aspects of tax controversy including income tax, estate tax, gift tax, employment tax, collection issues, penalties, and litigation in the U.S. Tax. Court. He represents clients in tax audits, collection defense, and litigation before the Internal Revenue Service, California Franchise Tax Board, Department of Fee and Tax Administration (formerly State Board of Equalization), Employment Development Department, and in the U.S. Tax Court and U.S. District Court. Mr. Oveisi has particular experience in tax matters involving Micro-Captive Insurance, Non-Cash Charitable Contributions, collection due process, and civil fraud.
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