Us.eversheds-sutherland.com
Wright and Ms. Goldner are located in New York and Ms. Rizzolo in Washington, D.C. 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 ... ................
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