A Miami-based consultancy is asking the US Tax Court to redetermine a $1.05 million liability from 2020 and 2021 for what the IRS called a tax abusive captive insurance arrangement.
GDA Consulting Group LLC and its partnership representative, Jairo Perez, accused the IRS of making arbitrary and capricious adjustments to GDA’s income in two lawsuits the company served Monday. The agency disallowed deductions GDA claimed for property and casualty insurance premium payments to two Tennessee captive insurance entities, Bravura Insurance Co. and Noble Insurance Co., which the IRS said lacked economic substance.
- Bravura and Noble paid significant claims under their ...
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