Divided Tax Court Finds Insurance Premiums Paid By Subsidiaries To Captive “Brother” Insurance Corporation Deductible

Overview


Tom Jones discussed a divided opinion by the U.S. Tax Court, finding that insurance premium payments made by subsidiaries of a parent company to a brother captive insurance corporation within the same controlled group were deductible expenses. Mr. Jones explained that even though the Sixth Circuit in 1987’s Humana decision had reversed this portion of the Tax Court’s ruling, the Tax Court had never officially ruled again on this brother-sister approach until now. Read the full article