On March 10, 2020, the owners of Puglisi Egg Farms of Delaware and its related captive insurance company filed petitions in the U.S. Tax Court to contest an IRS administrative determination concerning the tax treatment of its insurance under the Oxford Insurance Company LLC structure. Puglisi Egg Farms is a Delaware agribusiness that focuses on egg production.
We have been aware of this case for some time and will cooperate fully in the Tax Court proceedings to defend the insurance policies and the insurance company. The IRS written determination contained no analysis of the insurance arrangement’s risk shifting, risk distribution, insurable risk, or common notions of insurance. We are confident that the Tax Court will conduct an objective review of the insurance arrangement and conclude that the arrangement satisfies the tax law.