Byline: Two Identical Private Letter Rulings By the IRS Hold Domestic Captive Insurance Arrangement with Reinsurer Deemed ‘Insurance’ for Federal Tax Purposes
By Krista S. Kovalcin, FPCA Legal Team On December 11, 2009, the Internal Revenue Service ("IRS") issued two identical Private Letter Rulings (PLRs) in 200950016 and 200950017. The PLRs each held that, where there was risk shifting and risk distribution present in an arrangement involving a domestic captive reinsurer that was solely in the business [...]