Tax Court Follows Avrahami Analysis in Reserve Mechanical Decision

Posted By: alliantgroup June 22, 2018

The US Tax Court issued its decision in Avrahami v. Comm’r of Internal Revenue, No. 17594-13, the earliest Tax Court opinion involving a micro-captive. On June 18, a second case has joined its ranks with the ruling in Reserve Mechanical v. Comm’r of Internal Revenue, No. 14545-16.

While it involved a small insurance company and whether it qualified under Internal Revenue Code section 501(c)(15),Reserve Mechanical provided additional information about the Tax Court’s views on captives and what the court considers insurance in that context. Captive insurance owners and managers should note that even though the taxpayer’s facts in both cases were slightly different, the Court’s underlying analysis of the issues remained similar.

Click here to read the full article detailing the case.

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alliantgroup
alliantgroup’s mission is one of education and awareness—we exist to help industry organizations, businesses and the accounting firms that advise them take full advantage of all federal and state tax credits, incentives and deductions available. These powerful incentive programs are legislated by the government to help businesses grow and remain competitive locally as well as abroad. We are proud to have helped over 16,000 businesses claim more than $8 billion in tax incentives. alliantgroup’s international headquarters is in Houston, Texas, with offices across the country and internationally including New York, Boston, Chicago, Orange County, Sacramento, Indianapolis, Washington, D.C and London and Bristol in the U.K.