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ARTICLE · 16 FEBRUARY 2026

Captive Insurance: When The IRS Comes Knocking (Podcast)

ArentFox Schiff
ArentFox Schiff
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In the latest episode of "Tax Stuff You Should Know," hosts Bob Pluth and Gene Magidenko unpack the CFM Insurance decision, spotlighting the complexities of captive insurance...

United StatesInsurance
Robert R. Pluth, Jr.
Robert R. Pluth, Jr.
Evgeny Magidenko
Evgeny Magidenko

In the latest episode of "Tax Stuff You Should Know," hosts Bob Pluth and Gene Magidenko unpack the CFM Insurance decision, spotlighting the complexities of captive insurance arrangements and the Internal Revenue Service's (IRS) scrutiny of them.

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They underscore the importance of tax planning needing to correspond with economic and substantive reality, the audit risks, including those tied to refund claims, and the implications of the IRS' Dirty Dozen list. The discussion also stresses the importance of meticulous documentation and legal compliance, and notes that reliance on qualified professional advice can help mitigate penalties.

Takeaways

  • Captive insurance companies must operate as bona fide insurance providers.

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