Much like Avrahami, the Reserve Mechanical case is another notch on the IRS’s belt as it continues on its warpath against small captives, hurting the legitimate structures in the process. But what went wrong? Matthew Queen of Venture Captive Management breaks it down.
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Capstone Associated Services, the operator of Reserve Mechanical's risk pool entity Pool Re Insurance, has issued a second statement on the US Tax Court case following the opinion issued by Judge Kathleen Kerrigan.