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Self Insurers and Risk Managers Committee Newsletter - Winter 2019

Syzygy Insurance - Another Microcaptive Does Not Meet the Test - In Syzygy Ins. Co. v. Comm’r of Internal Revenue, 117 T.C.M. (CCH) 1165 (T.C. 2019), Syzygy was a microcaptive insurance company established by the Highland Tank companies. Highland was closely held by the Jacob family. Syzygy was organized with assistance by Alta. Syzygy and Highland participated in Alta’s captive insurance program. Participants consisted of companies purchasing captive insurance and their related captive insurers. Typically, participants did not directly purchase policies from their captive insurers but from fronting carriers related to Alta.

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