In William R. Davis’ article “Small Captive Insurance Legislation Passes House,” Miller offers his thoughts on the effect.
Former acting IRS Commissioner Steven T. Miller, who is now national director of tax at alliantgroup, said the bill’s effect on the industry would be minimal. “My first read is that provided that the structure of the captive doesn’t have estate planning aspects to it, I don’t think it will have a large impact,” he said. The largest impact, he said, is that premiums will be increasing, which is a positive.
Although Congress addressed estate planning issues for small captives with “laser vision,” Miller said, estate planning is not the primary driver of small captive examinations. The primary drivers are whether the premiums are reasonable, the coverage is realistic, and the money is being used in a way congruent with a legitimate insurance company, he said.
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