Microcaptive Owners’ Bid For 5th Circuit Rehearing Denied In IRS Penalty Dispute

( September 12, 2025, 3:00 PM EDT) -- NEW ORLEANS — The Fifth Circuit U.S. Court of Appeals denied a petition for rehearing en banc filed by the owners of a microcaptive insurance company, leaving intact its decision that their microcaptive arrangements did not achieve risk distribution and therefore could not qualify as insurance for federal tax purposes....