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CONNECTICUT MOVERS JUNE 14, 2021 ■ 3

Captive Insurance Groups Celebrate SCOTUS

Win, With Support From Connecticut Team

By Michael Marciano

P.J. Cimini, left, president of the Connecticut Captive Insurance Association, and Cassie Bachman, right, of Elevate
Risk Solutions. Courtesy photos.

In a significant win for captive insurance The rule requires captive insurance companies
markets, the U.S. Supreme Court recently unan- to report detailed information about micro-captive
imously overturned a Sixth Circuit Court of transactions or face penalties for noncompliance.
Appeals ruling on tax reporting rules for captive In agreeing with the plaintiffs that their suit was
insurance companies, with Connecticut organiza- not filed specifically to avoid tax penalties but to
tions playing a key role. challenge the legality of the reporting rule itself,
Joining representatives from 24 other states, the Con- the Supreme Court rejected trial and appellate
necticut Captive Insurance Association contributed to court rulings that found CIC’s lawsuit was barred
an amicus curiae brief with assistance from students by the Anti-Injunction Act.
from the University of Connecticut School of Law and The Supreme Court wrote that notice 2016-
Yale Law School in CIC Servs., LLC v. Internal Revenue 66 “levies no tax. Rather, it compels taxpayers
Service et al, in which Justices Sonia Sotomayor and and their material advisors to collect and submit
Brett Kavanaugh issued concurring opinions in support detailed information about micro-captive
of CIC Services, a Knoxville, Tennessee-based captive transactions and their participants. And obey-
insurance manager that challenged IRS notice 2016-66. ■ Continued on PAGE 4

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