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What Was the IRS' Beef With Captives?

To learn more about captive insurance companies, please visit my webpage.

 

Starting in the mid-1970s, and continuing through the UPS case, the IRS fought captives tooth and nail.  Over the course of these cases, they advanced three different legal arguments against captive insurance: the economic family argument, the nexus of contracts and the assignment of income doctrine. 

However, it's important to ask this question regarding the IRS' legal battle: "what was it about captives that the IRS did

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