"For the last 16 years, we have successfully guided captive insurers administered by Capstone through IRS audits, IRS Appeals and the U.S. Tax Court," states tax attorney, Logan R. Gremillion. "The Firm is now offering its services on a case-by-case basis to those who are involved in varying stages of tax controversy with the Internal Revenue Service in the captive insurance area. Our Firm wishes to further use the tremendous experience which it has accumulated over the last 15 years along with its excellent track record.”
The Firm explains that, although IRS audits are infrequent, they are comprehensive, time consuming, and demand a significant amount of supporting legal and financial documentation. The design and implementation of captive insurance arrangements is an exacting and detailed process. "Most so-called 'captive insurance managers' disclaim all legal and tax consequences of the planning offered. In a captive tax audit, it is critical to have legal representation that has substantial experience in captive insurance taxation in order to address the Service's examination. All too often, the work of 'captive managers' work is incomplete," added Gremillion.
“We have recently represented three Capstone-administered captives in cases docketed in the U.S. Tax Court in which ultimately the IRS conceded the tax-payer's position in full, resulting in no change in tax due,” commented The Feldman Law Firm's tax department head, Steven D. Cohen. "This was a four-year process."
Another program offered by the Firm is a full-scale "health check up," in which all aspects of planning carried out by third-party "captive managers" is examined for Federal and state tax and domicile compliance. The Firm cautions that results cannot be guaranteed because each captive insurance case is determined on its own individual facts and circumstances.
For more general information on Capstone's work history in forming and operating captives, please complete the short form below.
Editor’s Notes: As of CURRENT_YEAR, Capstone has been operating for CAP_YEARS_NUMBER years and has formed over CAPTIVE_FORMATIONS captives. As of CURRENT_YEAR, The Feldman Law Firm has been operating for LAW_YEARS_NUMBER years and has successfully resolved over TAX_CONTROVERSIES tax controversies. The current cap on captive insurance premiums is CURRENT_PREMIUM_CAP million, which carries a 0% Federal income tax rate under Section 831(b) of the Internal Revenue Code.