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What Is “Insurance”? Lessons From The Captive Insurance Tax Controversy

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  • M. Moshe Porat
  • Michael R. Powers

Abstract

Over the past 30 years, the tax treatment of insurance premiums paid to captive (i.e., subsidiary) insurance companies has generated considerable controversy and litigation. In this article, we propose a new definition of insurance that is motivated by a careful analysis of the issues raised in the captive insurance tax controversy. Emphasizing the fundamental roles played by market forces and the efficiency of risk transfers, this new definition both broadens and refines traditional definitions of insurance.

Suggested Citation

  • M. Moshe Porat & Michael R. Powers, 1999. "What Is “Insurance”? Lessons From The Captive Insurance Tax Controversy," Risk Management and Insurance Review, American Risk and Insurance Association, vol. 2(2), pages 72-80, January.
  • Handle: RePEc:bla:rmgtin:v:2:y:1999:i:2:p:72-80
    DOI: j.1540-6296.1999.tb00053.x
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    File URL: https://doi.org/10.1111/j.1540-6296.1999.tb00053.x
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    Cited by:

    1. Powers, Michael R. & Shubik, Martin, 2001. "Toward a theory of reinsurance and retrocession," Insurance: Mathematics and Economics, Elsevier, vol. 29(2), pages 271-290, October.
    2. Powers, Michael R. & Venezian, Emilio C. & Juca, Iana B., 2003. "Of happy and hapless regulators: the asymptotics of ruin," Insurance: Mathematics and Economics, Elsevier, vol. 32(2), pages 317-330, April.

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