What Tax Professionals Need to Know Now About IRS Scrutiny, Micro-Captive Rules & Compliance

Captive insurance arrangements are facing heightened IRS scrutiny and increased enforcement, making it more important than ever for tax professionals, CPAs, attorneys, financial advisors, and business owners to understand the evolving rules surrounding IRC §§ 831(a) and 831(b).

With the Final IRS Micro-Captive Regulations, recent federal court decisions, expanding reporting requirements, and heightened enforcement activity, captive insurance structures are receiving closer attention from the IRS. Understanding the current rules and identifying potential compliance and audit risks is critical for professionals advising clients with existing or proposed captive arrangements.

This timely 2-hour course provides a practical update on the 2026 captive insurance landscape, covering the latest IRS developments, taxation under IRC §§ 831(a) and 831(b), eligibility requirements, reporting obligations, risk distribution, premium deductibility, audit triggers, and strategies for maintaining compliant captive insurance programs.

Whether you currently advise clients with captive insurance arrangements or are considering whether a captive structure is appropriate, this session will help you identify emerging risks, understand the latest regulatory developments, and make more informed planning decisions.

Learning Objectives:

  • Understand the latest IRS developments affecting captive insurance companies
  • Navigate the Final IRS Micro-Captive Regulations
  • Differentiate between IRC § 831(a) and IRC § 831(b) taxation
  • Determine eligibility requirements for the IRC § 831(b) election
  • Evaluate captive insurance structures and their underlying business purposes
  • Understand why micro-captive arrangements are receiving increased IRS scrutiny
  • Review recent federal court decisions and their implications for taxpayers
  • Identify current IRS enforcement priorities and potential audit triggers
  • Understand Transactions of Interest, Listed Transactions, and related disclosure obligations
  • Evaluate risk distribution and risk shifting requirements
  • Understand premium deductibility considerations
  • Identify documentation, governance, and reporting requirements
  • Recognize potential compliance weaknesses before they become audit issues
  • Explore strategies for maintaining a defensible and compliant captive insurance program
  • Understand considerations surrounding the revocation of an IRC § 831(b) election

Session Highlights:

  • 2026 IRS Developments in Captive Insurance
  • IRC §§ 831(a) and 831(b): Key Differences
  • Final IRS Micro-Captive Regulations
  • Increased IRS Scrutiny of Micro-Captive Arrangements
  • Recent Federal Court Decisions
  • Current IRS Enforcement Priorities
  • Transactions of Interest vs. Listed Transactions
  • Reporting and Disclosure Requirements
  • Risk Distribution and Risk Shifting
  • Premium Deductibility
  • Documentation and Corporate Governance
  • Common Captive Insurance Audit Triggers
  • Compliance Risks and Mitigation Strategies
  • Revoking an IRC § 831(b) Election
  • Practical Captive Insurance Case Studies
  • Future Regulatory and Enforcement Outlook

Credits and Other information :

  • IRS CPE Credits: 2.0 TAX
  • Location: Virtual/Online
  • Delivery method: Group Internet Based
  • IRS Course ID: DFFSC
  • Attendance Requirement: Yes
  • Session Duration: 2 Hours
  • Case Studies and Live Q&A session with speaker
  • PowerPoint presentation for reference

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Each webinar wraps up with a Q&A session, giving you the opportunity to interact with industry experts and receive answers to all your queries.

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  • IRS
  • HRCI
  • SHRM

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