TECHNICAL MEMORANDUM: Avrahami v. Commissioner

On August 21, 2017, the Tax Court released its eagerly-awaited opinion in the consolidated cases, Benyamin Avrahami and Orna Avrahami v. Commissioner and Feedback Insurance Company, Ltd. v. Commissioner; the first court case involving a so-called “micro-captive transaction”. The decision was a mixed-bag. While the Petitioners lost on almost every issue, the Court’s decision was very much factspecific. So, it is not clear what this case means for micro-captive transactions with different facts.

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