The Captive Insurance Companies Association ("CICA"), a trade association representing the captive insurance industry, has issued a statement on section 831(b) companies with cautionary language: The traditional captive insurance company industry and CICA are extremely concerned about the misuse of small captives utilizing the IRC 831(b) election and the attendant publicity about "captives" being a tax avoidance device. Although there is nothing wrong with the utilization of the 831(b) election when a small captive insurance company is truly engaged in insuring the risk of its parent company/owner(s), the traditional captive insurance industry strongly opposes the utilization of small 831(b) captives primarily for tax sheltering purposes. In simple language, do 831(b)s right or don't do them at all!
412I IRS AUDITS, LISTED TRANSACTIONS
ReplyDeleteApril 24, 2012
By Lance Wallach, CLU, CHFC
Some of the Section 419 Welfare Benefit Plans:
ReplyDeleteNOVA Benefit Plans (run or had been run by Dan Carpenter, Wayne Bursey, Guy Neumann, Kathy Kehoe, Joe Castagno and others), including: the SADI Plan, the Grist Mill Plan, Life One, among others
Benistar Plans (also run or had been run by Dan Carpenter, Wayne Bursey, Guy Neumann, Kathy Kehoe, Joe Castagno and others)
Greater Metropolitan
Sterling Benefit Plan (run by Ronald Snyder)
Millenium Plans
CJA & Associates (run by Raymond Ankner)
Sea Nine VEBA
Compass Welfare Benefit Plan
Sunderlage Resource Group/SRG International (run by Tracy Sunderlage, among others)
Restricted Property Trust (RPT) (run by Ken Crabb)