Now You Own It, Now You Don't: IRS Clarifies Taxation Of Rent-A-Captives

Extract

---

Now You Own It, Now You Don't: IRS Clarifies Taxation Of Rent-A-Captives

This article originally appeared in the April

2008 issue of Captive Review.

When you rent a captive, is it taxed as if you own it? The

IRS recently resolved that question in Revenue Ruling 2008-8.

The ruling holds that if a rent-a-captive cell satisfies the

tax definitional requirements of an insurance company, it will

be treated as a standalone insurance company despite the

cell's lack separate legal statu...

See the full content of this document

---