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Tax Notes Quotes Rachel Partain on Captive Arrangements

July 8, 2020, Tax Notes

The government has called on the Tenth Circuit to endorse the Tax Court’s decision finding an offshore captive insurer’s arrangement invalid because, among other things, it lacked sufficient risk distribution.

. . .

According to Rachel L. Partain of Caplin & Drysdale, the government’s brief also falls short in its response to a February 27 amici curiae brief filed by industry groups, which argued that the Tax Court mischaracterized the risk pooling arrangement as a circular flow of funds.

. . .

The government’s brief, however, didn’t address that point but rather points to another explanation for why the reinsurance premiums received by the captives from PoolRe equal the stop-loss premiums ceded by the captives to PoolRe, Partain said.

For the full article, please visit Tax Notes’ website (subscription required).

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