The U.S. Department of the Treasury has finally regulations to deal with so-called microcaptive transactions.
Microcaptives are, for the most part, insurance companies that attempt to qualify for treatment under section 831(b) of the Internal Revenue Code by way of a shared risk-pool arrangement which only superficially provides risk sharing and risk distribution for tax purposes, and whose real purpose is to provide inflated deductions for the businesses that the microcaptives are insuring.
Read the Full Article: https://www.forbes.com/sites/jayadkisson/2023/04/11/us-treasury-department-issues-proposed-regulations-to-finally-eviscerate-microcaptive-tax-shelters/