Ensuring that the IRS treats an insurer as an insurer for tax purposes is critically important for captive insurance companies. This may sound simple, but it can get complicated in certain captive situations. A captive insurance company must be considered to be an insurer by the IRS for the premiums paid to be deductible. A summary article on the subject can be found at WebCPA (see here): The IRS states that for a transaction to be considered insurance, both ?risk...
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