Following the tumultuous tax issues that dominated 2007 into 2008–changes that could have altered the captive industry–this year by comparison has been relatively tame.
While there have been several developments on the taxation of captive insurance this year, they generally did not expand the status quo. This is not surprising, as there were not many "hot button" issues scheduled on the IRS agenda. (See NU, "Tax Challenges Remain for Captive Entities," March 9, 2009.)
An issue potentially relevant to captives is the IRS Business Plan. Each year, the IRS publishes a Business Plan–technically called its "Priority Guidance Plan"–which lists projects on which the IRS hopes to issue a public position (generally referred to as "guidance").
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