Segregated Cell Captive Taxation

Rent-a-captives have been around for many years, and provide a captive insurance alternative with little or no upfront investment. Segregated or protected cell captive insurance companies (see here & here) are a newer and simpler structure for rent-a-captives which have been created through enabling legislation in a number of off-shore and on-shore captive domiciles. While the tax treatment of insurance premiums paid to rent-a-captive arrangements is not always clear, the IRS issued Revenue Ruling 1008-08 to provide some guidance. Two...