IRS Scrutiny of Abusive Structures

  • Not Following the Safe Harbor Guidelines
  • No Real Distribution of Risk
  • No Claims Experience or Claims Layering
  • High Deductible Risk Pools or Retroactive Policy Issuance
  • Lack of Business Purpose
  • Implementing a Captive to Obtain Tax Deductible Life Insurance
  • Tax Opinion Written by an Interested Party
  • Insuring Unreasonable Risks
  • Paying Excessive Premium for your Coverage
  • Treating Captive Assets as a Personal Checkbook
  • Circular Transactions
  • Investment Plans that Don’t Make Sense

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