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In this Discussion, please respond to the following questions: Avrahami, Reserve Mechanical and Caylor Do you agree with the outcome of Avrahami, Reserve Mechanical and

In this Discussion, please respond to the following questions:

Avrahami, Reserve Mechanical and Caylor

  1. Do you agree with the outcome of Avrahami, Reserve Mechanical and Caylor?
  2. How do non-traditional risk structures pass muster from a tax perspective given these outcomes?
  3. Can any 831(b) captive stand a chance in tax court?
  4. Given the outcome in Caylor, where does that leave us?

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