On April 10, 2019, the U.S. Tax Court published their ruling on the Syzygy Insurance Company case that concluded the micro-captive was not insurance in the commonly accepted sense.
As with similar cases that have gone before (i.e. Avrahami), the Tax Court memo opinion is great news for the captive industry as it brings clarity to the use of 831(b) arrangements and helps highlight features of non-compliant programs. It provides a clear picture of what “not to do” when structuring and managing a micro-captive arrangement, and also provides additional clarity and reaffirmation of many of the best practices employed by Oxford Risk Management Group.
If you have any additional questions, please contact your Oxford representative to arrange a call to discuss further at 410-472-6490 or Contact@OxfordRMG.com.