The IRS lost another challenge to captives in the recent Securitas tax court case. Captives help businesses improve risk management and build liquid loss reserve investment portfolios to protect the enterprise from an ever increasing risk environment which is especially true for US businesses today. Over 90% of the world’s litigation and regulatory actions are in the US. It is unfortunate the IRS continues challenging captives rather than publishing more definitive guidance to prevent practices it feels are abuses. Click here to read an excellent summary by a tax CPA of the recent Tax Court victory for captives that further amplifies the findings of the Rent-A-Center case that risk distribution is not merely measured by number of insured companies.