It’s no secret that Oxford, along with the captive insurance industry has been under IRS scrutiny for their insurance programs involving 831(b) elections, even though Congress created and has continually validated the elections. Often not reported, the IRS has conceded dozens of Oxford captive cases once they advanced to tax court. One argument for concessions is that multiple federal courts have recognized that the policies issued through Oxford are, in fact, valid insurance. Read the recent article by Tax Notes, claiming that the IRS may have picked the wrong fight with Oxford.