What the Sophisticated Advisor Needs To Know About Captive Insurance Companies

The past few years have been very eventful for 831(b) captive insurance companies, the business owners that implemented them and the advisors who provided guidance along the way. The PATH Act increased the annual contribution limit to $2.35 million and also implemented complicated diversification/ownership rules. The IRS then issued Notice 2016-66, which identified certain captive insurance companies as "transactions of interest." New disclosure obligations were required with Form 8886, while "Material Advisors" had to disclose on form 8918 details of their own involvement as well as maintain lists of clients engaged in transactions identified in the Notice. In 2019, the Service announced a comprehensive "Settlement Initiative" program in IR-2019-157, and in 2020 the IRS sent thousands of "soft warning" letters 831(b) Risk-Pooled Captive owners.

The best way for advisors to understand these significant changes is to purchase LISI's MasterClass "What the Sophisticated Advisor Needs To Know About Captive Insurance Companies." Comprised of 5 LISI Webinars and 20 LISI Newsletters, this MasterClass gives the sophisticated advisor everything needed to stay current with the avalanche of IRS guidance and court cases impacting captives. Here's a breakdown of what your MasterClass includes:

LISI Webinars

  • Mike DiMayo: How To Use 831(a) Captives To Protect Against the Loss of an Uninsurable Business Owner or Key Employee
  • Jay Adkisson & David Neufeld: Captive Insurance and the IRS Settlement Initiative In Perspective - IR-2019-157: Gift Season Came Early this Year for Taxpayers with Abusive Captive Insurance Arrangements
  • Jay Adkisson: 831(b) Captive Insurance State of the Union
  • Mike DiMayo: The Future of Captive Insurance Planning - New Tax Court Guidance and What the Future Holds
  • Mike DiMayo: What Advisors Need To Know About Captive Insurance Companies After the PATH ACT and Notice 2016-66

LISI Newsletters

  • Mike DiMayo: Specialty 831(a) Captive Solutions for Uninsurable Clients, Asset Protection Planning Newsletter #403 2020-04-28
  • Jay Adkisson: IRS Sends Soft Warning Letters to Thousands of 831(b) Risk-Pooled Captive Owners, Asset Protection Planning Newsletter #401 2020-04-08
  • Jay Adkisson on IR-2020-26: 80% of Offered Taxpayers Accept 831(b) Global Settlement Terms & IRS Creates 12 New Examination Teams, Asset Protection Planning Newsletter #397 2020-02-12
  • David S. Neufeld on IR-2019-157: IRS Pitches Its Micro-Captive Settlement Offer, Is It a Home Run or a Strikeout For Taxpayers, Asset Protection Planning Newsletter #394 2019-10-01
  • Jay Adkisson on News Release IR-2019-157: Christmas Came Early this Year for Taxpayers with Abusive Captive Insurance Arrangements, Asset Protection Planning Newsletter #392 2019-09-24
  • Colvin, Gutting & Slenn: Key Issues for Micro-Captives During an IRS Audit, Asset Protection Planning Newsletter #386 2019-06-06
  • Jay Adkisson on Syzygy Ins. Co. v. CIR: Third U.S. Tax Court Opinion on Risk-Pooled 831(b) Captive Insurance Companies Ends with Denied Deductions and Heavy Criticism of Life Insurance Inside a Captive, Asset Protection Planning Newsletter #383 2019-04-29
  • Dave Slenn: Micro-Captives & the IRS's Dirty Dozen List, Asset Protection Planning Newsletter #381 2019-04-22
  • Jay Adkisson on Shivkov v. Artex Risk Solutions: First Class Action Filed for Abusive 831(b) Risk-Pooled Captive Insurance Tax Shelters, Asset Protection Planning Newsletter #377 2018-12-12
  • David Slenn & Small Captive Insurance Program Exit Planning, Steve Leimberg's Asset Protection Planning Newsletter #374 2018-09-06
  • Jay Adkisson on Reserve Mechanical Corp. v. Commissioner: Risk-Pooled Small Captive Insurance Companies Take Bad Beating in Reserve Mechanical, Asset Protection Planning Newsletter #370 2018-06-26
  • Steve Leimberg: Captive Insurance Deskbook for the Business Lawyer - A Review, Asset Protection Planning Newsletter #365 2018-04-16
  • Jay Adkisson & David Slenn on Avrahami v. Commissioner: Tax Court Disallows Deductions for Captive Insurance Premiums, Asset Protection Planning Newsletter #353 2017-10-30
  • Jay Adkisson on Avrahami v. Commissioner - Tax Court Disallows Deductions for Captive Insurance Premiums, Asset Protection Planning Newsletter #349 2017-08-22
  • David Neufeld: Those Vexing Notice 2016-66 Questions, Asset Protection Planning Newsletter #340 2017-03-13
  • Chris Riser & Jay Adkisson: Notice 2016-66, Asset Protection Planning Newsletter #335 2016-12-05
  • David Neufeld on Notice 2016-66: IRS Requires Information Disclosures Regarding Certain Section 831(b) Captive Insurance Companies, Asset Protection Planning Newsletter #333 2016-11-28
  • Jay Adkisson, Chris Riser & Dave Slenn on Notice 2016-66: IRS Issues Long-Anticipated Notice of Its Intent to Combat Real and Perceived Abuses Involving 831(b) Captive Insurance Companies, Estate Planning Newsletter #2473 2016-11-02
  • Jeff Getty: Saving Your Business Owner Clients and Their Trusts from Potential Captive Insurance Company Disqualification in Light of the Proposed 2704 Regulations, Asset Protection Planning Newsletter #330 2016-09-14
  • Chris Riser, Jay Adkisson & David Slenn: Understanding How the PATH Act Impacts Section 831(b) Captives, Asset Protection Planning Newsletter #312 2016-01-19




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