US tax court rules against captive’s stop-loss insurance transactions, citing Avrahami

The US tax court has ruled that a risk pool operating as a stop-loss insurer was not operated as a bona fide insurance company and the transactions between it and its captive insureds were not insurance transactions, citing the Avrahami ruling. However, the decision has been described by Capstone Associated Services, a captive services firm based in Houston, and the…

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