Capital Management
Consulting, LLC
IRS Revenue Rulings
Rev. Ruling 2001-31
Premium Deductions: The IRS will no longer invoke the economic family theory with respect to captive insurance transactions.
2 (Revenue Ruling 2001-31).rtf
Text document [6.1 KB]
Premium Deductions: The IRS will no longer invoke the economic family theory with respect to captive insurance transactions.
2 (Revenue Ruling 2001-31).rtf
Text document [6.1 KB]
Rev. Ruling 2002-75
Annuity Contracts: Tax-free exchanges: Insurance Companies: Basis: Investment in Contracts.
6 (Revenue Ruling 2002-75).rtf
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Annuity Contracts: Tax-free exchanges: Insurance Companies: Basis: Investment in Contracts.
6 (Revenue Ruling 2002-75).rtf
Text document [8.0 KB]
Rev. Ruling 2002-89
Business Deductions: Insurance premiums: Risk Shifting Safe Harbor - 50% 3rd Party
7 (Revenue Ruling 2002-89).rtf
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Business Deductions: Insurance premiums: Risk Shifting Safe Harbor - 50% 3rd Party
7 (Revenue Ruling 2002-89).rtf
Text document [10.8 KB]
Rev. Ruling 2002-90
Business Deductions: Insurance Premiums: Risk Shifting Safe Harbor - 12 Entity Standard
8 (Revenue Ruling 2002-90).rtf
Text document [9.9 KB]
Business Deductions: Insurance Premiums: Risk Shifting Safe Harbor - 12 Entity Standard
8 (Revenue Ruling 2002-90).rtf
Text document [9.9 KB]
Rev. Ruling 2002-91
Group Captive Insurance Companies: Insurance Premiums: Risk Shifting
9 (Revenue Ruling 2002-91).rtf
Text document [13.3 KB]
Group Captive Insurance Companies: Insurance Premiums: Risk Shifting
9 (Revenue Ruling 2002-91).rtf
Text document [13.3 KB]
Rev. Ruling 2005-40
The IRS analyzed four hypothetical captive arrangements and concluded that three of the four lacked risk distribution. Prior to 2005-40, the IRS's position on risk distribution was unclear, primarily
13 (Revenue Ruling 2005-40).rtf
Text document [19.7 KB]
The IRS analyzed four hypothetical captive arrangements and concluded that three of the four lacked risk distribution. Prior to 2005-40, the IRS's position on risk distribution was unclear, primarily
13 (Revenue Ruling 2005-40).rtf
Text document [19.7 KB]
IRS Revenue Procedures
Rev. Proc. 2002-3
Advance rulings: Areas of non-issuance determination letters
3 (Revenue Procedure 2002-3).rtf
Text document [27.1 KB]
Advance rulings: Areas of non-issuance determination letters
3 (Revenue Procedure 2002-3).rtf
Text document [27.1 KB]
Rev. Proc. 2002-75
Advance rulings: Areas of non-issuance: Captive insurance companies
5 (Revenue Procedure 2002-75).rtf
Text document [9.7 KB]
Advance rulings: Areas of non-issuance: Captive insurance companies
5 (Revenue Procedure 2002-75).rtf
Text document [9.7 KB]
IRS Notices
Notice 2002-70
Insurance Companies: Sham transactions: Reinsurance arrangements: Allocation: Listed Transactions
4 (Notice 2002-70).rtf
Text document [15.3 KB]
Insurance Companies: Sham transactions: Reinsurance arrangements: Allocation: Listed Transactions
4 (Notice 2002-70).rtf
Text document [15.3 KB]
Notice 2003-75
To qualify as an insurance company, the company must have adequate risk shifting and risk distribution.
10 (Notice 2003-35).rtf
Text document [5.4 KB]
To qualify as an insurance company, the company must have adequate risk shifting and risk distribution.
10 (Notice 2003-35).rtf
Text document [5.4 KB]
Notice 2004-64
501(c)(15) - total revenues $600,000 or less with investment income not to exceed 50% of revenues.
11 (Notice 2004-64).rtf
Text document [9.2 KB]
501(c)(15) - total revenues $600,000 or less with investment income not to exceed 50% of revenues.
11 (Notice 2004-64).rtf
Text document [9.2 KB]
Notice 2004-65
Producer-owned reinsurance companies no longer considered a listed transaction.
12 (Notice 2004-65).rtf
Text document [11.1 KB]
Producer-owned reinsurance companies no longer considered a listed transaction.
12 (Notice 2004-65).rtf
Text document [11.1 KB]
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