This section includes a broad range of general background information, including a discussion of pre-2017 requirements for the qualification of a mini-captive, the blanket audit program initiated by the IRS, an analysis of the various bases for the denial of section 831(b) treatment by the IRS, as well as significant procedural and evidentiary requirements relevant to Tax Court litigation.

MiniCapNews Members Only

This page is restricted to MiniCapNews members only. Become a MiniCapNews subscriber for just $500 per year. Subscribers receive access to analytical materials, quarterly newsletters and periodic supplemental information related to mini-captive insurance. Learn more about MiniCapNews membership. SUBSCRIBE NOW Already a subscriber? Sign in.