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The Service concluded, in effect, that the coverage can qualify as
insurance and the premiums paid to the insurer may be deductible as insurance
premiums, although the insurer had no owners other than the 3 6
funds. More funds transferred risks under the arrangement than the 3 1
corporations that transferred their risks in Revenue Ruling
78-338.
In Revenue Ruling 2002-91,169 a group of unrelated businesses in an
industry that faced significant liability hazards and were required by regulators
to maintain adequate liability coverage could not obtain affordable
insurance from commercial insurers as a result of significant losses from
unusually severe loss events. The taxpayer and a significant number of
other businesses in the industry formed a group captive to provide insurance
liability coverage for certain
risks.
The group captive provided coverage only for the taxpayer and other
members. No member owned more than 15 percent of the group captive
and no member held more than 15 percent of any corporate governance
issue. The group captive was adequately capitalized and its operations
were independent of the operations of each of its members.
The premiums that the group captive charged were determined using
actuarial techniques and were based, in part, on commercial rates for
similar coverage. The group captive pooled premiums from its members
and no member had to pay additional premiums if its losses in any period
exceeded the premiums that it paid. No member received a refund if its
losses were lower than its premiums.
