The Tax Court recently determined that the captive insurance arrangement regarding SHI Group, a subsidiary of the Swedish company Securitas AB, constituted insurance. According to the ruling, the insurance premiums paid by SHI Group are deductible, as in accordance with the Internal Revenue Code. This effectively overturns IRS’s disallowance of the deductions in 2003 and 2004.
See No. 21206-10, T.C. Memo. 2014-225 (U.S.T.C. Oct. 29, 2014).
Posted by Elizabeth Cheung, Associate Editor, Wealth Strategies Journal.