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For years the Internal Revenue Service has essentially been saying that if it “walks like a duck and talks like a duck, for all intents and purposes, it is a duck”–or in the case of captives, an insurance company. But captive insurers beware: the definition of a “duck” can get murky, as with multimember LLCs (limited liability corporations) and limited partnerships.

As has been the case for some time, the IRS is examining gray areas and has revoked tax exemptions for two section 501(c)(15) captive insurance companies– this time in Chief Counsel Advice (CCA) 200952060 and CCA 200952061.

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