Skip to Main Content

Tax Notes Quotes Rachel Partain on Captive Insurance

September 29, 2020, Tax Notes

A captive insurance company is arguing that its case before the Tenth Circuit turns on whether the Tax Court erroneously applied the law, but says the government’s response sidestepped that issue. 

. . .

Reserve “has the better argument on the characterization of the payments to the captive,” Rachel L. Partain of Caplin & Drysdale told Tax Notes September 28, noting the company’s citation of Sammons — a Tax Court decision in the captive context.

“Reserve’s arguments on why BrokerTec is not relevant is persuasive, and grounded in the insured-captive-owner structure,” Partain added. 

For the full article, please visit Tax Notes’ website (subscription required).


About Caplin & Drysdale
Celebrating our 55th Anniversary in 2019, Caplin & Drysdale continues to be a leading provider of legal services to corporations, individuals, and nonprofits throughout the United States and around the world. We are also privileged to serve as legal advisors to accounting firms, financial institutions, law firms, and other professional services organizations.

The firm's reputation over the years has earned us the trust and respect of clients, industry peers, and government agencies. Moreover, clients rely on our broad knowledge of the law and our keen insights into their business concerns and personal interests. Our lawyers' strong tactical and problem-solving skills -- combined with substantial experience handling a variety of complex, high stakes, matters in a boutique environment -- make us one the nation's most distinctive law firms.

With offices in New York City and Washington, D.C., Caplin & Drysdale's core practice areas include:
For more information, please visit us at
Washington, DC Office:
One Thomas Circle NW
Suite 1100
Washington, DC 20005
New York, NY Office:
600 Lexington Avenue
21st Floor
New York, NY 10022


This communication does not provide legal advice, nor does it create an attorney-client relationship with you or any other reader. If you require legal guidance in any specific situation, you should engage a qualified lawyer for that purpose. Prior results do not guarantee a similar outcome.

Attorney Advertising
It is possible that under the laws, rules, or regulations of certain jurisdictions, this may be construed as an advertisement or solicitation.
©2021 Caplin & Drysdale, Chartered
All Rights Reserved.

Related Practice Area(s)