This is the first book on captive insurance which thoroughly examines the relevant issues associated with starting a captive insurance company. Part I begins with a description of the companies most likely to benefit from a captive program. This is followed by a detailed outline and explanation of the formation process and ends with an overview of the tax issues encountered by a property and casualty insurance company.
Part II presents the first in-depth historical analysis of the entire history of U.S. captive insurance case law. It begins with the reserve cases of the early 20th century and is followed by the flood plane cases of the 1950s, the I.R.S. victories of the 1980s, the taxpayer victories of the 1990s and the I.R.S.’ safe harbor Revenue Rulings of the early 2000s.
With over 950 footnotes and 40 sources, this is the most complete treatment of captive insurance to date.