For your CPA.

What changed and why it matters.

Listed Transaction

Struck down. Vacated by a federal court April 2026. The harshest label, gone.

Transaction of Interest

The disclosure is filed for you as part of administration. Currently on appeal at the Fifth Circuit.

What it means for you

Our Micro Captives are built with the same discipline as every other tax-advantaged vehicle in the code.

Will this trigger an audit?

No, our administrator has filed thousands of these disclosures for 1,000+ insureds. Per its public statement, "not one of [its] clients has been audited due to these filings." The plan includes funded legal and accounting support if examined.

"Despite this extraordinary transparency, not one of [its] clients has been audited due to these filings."

our administrator's public statement, June 2025