Risk Distribution in captives: aligning tax court vs underwriting
- Actomate

- Sep 24, 2025
- 1 min read
The piece contrasts Tax Court metrics (e.g., Swift v. CIR) with exposure‑based underwriting. It explores scale, correlation, and pooling mechanics. Offers practical documentation tactics. Useful for actuarial sign‑off and tax counsel alignment. Reduces controversy risk. (captives.insure)
Source: Captives.insure




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