Ruling A Microcaptive Arrangement Not Insurance, Tax Court Upholds Penalties

(January 10, 2024, 8:50 AM EST) -- WASHINGTON, D.C. — A microcaptive arrangement was “not insurance for federal income tax purposes,” and the three shareholders of a California corporation are liable for accuracy-related penalties totaling 20% of the amount the corporation understated income tax from 2012 to 2014 as a result, a U.S. Tax Court judge ruled....