Beckett G. Cantley & F. Hale Stewart, IRS Loses Captive Insurance Case on Good Taxpayer Facts, Tax Notes (November 17, 2014).
Summary: In this Tax Analysts article, Prof. Cantley and F. Hale Stewart discuss why they believe the next wave of captive litigation cases will be more fruitful for the IRS, and why practitioners should be cautious. Tax Notes, Nov. 17, 2014