How the CFM Decision Is Reshaping Captive Insurance Tax Standards

Podcast: The Edge of Risk Podcast by IRMI · irmi

Opublikowano: 2026-05-08

Recorded live at the Captive Insurance Companies Association 2026 International Conference, this episode of The Edge of Risk Podcast by IRMI features Kristen Lawler discussing one of the most closely watched captive insurance tax decisions in recent years: the 2025 CFM Insurance Tax Court memorandum opinion. Drawing from her recent article in IRMI's publication Captive Insurance Company Reports, Ms. Lawler explains how the case highlights the growing importance of operational discipline, governance, documentation, pricing support, and claims handling in determining whether a captive arrangement qualifies as insurance for federal tax purposes. The discussion explores the "commonly accepted notions" prong...