Home - Eversheds Sutherland
In Humana Inc. v. Commissioner, 881 F.2d 247 (6th Cir., 1989), the Court stated, in essence, that if premiums were paid from an operating subsidiary to a subsidiary which was a captive insurance company there was a transfer of risk because the losses would be transferred from the balance sheet of the operating subsidiary to the balance sheet of ... ................
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