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Why U.S. Tax Court Ruled in Favor of IRS in Avrahami Captive Case


In August 2017, the U.S. Tax Court released its decision in the Avrahami case. The ruling marked the first case that involved a captive that had made the election to be taxed solely on investment income under Section 831(b), also referred to as the micro captive strategy.

Alan Fine, Partner in Charge, Insurance and Captive Insurance Services, recently discussed the aftermath of the decision in a Captive Insurance Times article. Click here to find out why the Tax Court ruled in favor of the Internal Revenue Service (IRS). 


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