When Are Premiums Paid to a Captive Insurance Company Deductible for Federal Income Tax Purposes?

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When Are Premiums Paid to a Captive Insurance Company Deductible for Federal Income Tax Purposes?

April 01, 2026

United States
United States
United States
Captive.com

In an article published by Captive.com, Eversheds Sutherland attorneys Saren Goldner, Kriss Rizzolo, and Bruce Wright examine when premiums paid to a captive insurance company are deductible for federal income tax purposes. The authors explain that deductibility turns on whether the captive arrangement will be respected as “true insurance,” focusing on factors such as risk transfer, risk distribution, and alignment with commonly accepted notions of insurance under IRS guidance and case law.

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Key contacts

sarengoldner@eversheds-sutherland.com

Saren Goldner

Partner

New York, United States

kristanrizzolo@eversheds-sutherland.com

M. Kristan Rizzolo

Senior Counsel

Washington, DC, United States

brucewright@eversheds-sutherland.com

P. Bruce Wright

Of Counsel

New York, United States

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