Captive Insurance and Self-Procurement Tax: Key Considerations

Self-procurement tax is an often overlooked aspect of captive insurance that can create significant compliance and financial implications if not properly addressed. In this episode of The Edge of Risk Podcast by IRMI, host Joel Appelbaum is joined by Allan Autry, CPA and partner at Johnson Lambert, to explore when self-procurement tax applies, why it exists, and how it affects organizations using captive insurance companies. Allan explains the distinction between premium tax and self-procurement tax, discusses the impact of the Nonadmitted and Reinsurance Reform Act, and outlines how an insured's home state is determined for tax purposes. The conversation also examines common misconceptions surrounding self-procurement tax, practical compliance considerations, and the challenges organizations face when operating across multiple jurisdictions. Allan shares insights on how self-procurement tax can influence captive domicile decisions, why it should be included in feasibility studies, and how fronting arrangements may alter tax obligations. The discussion concludes with a look at increasing state enforcement activity and steps captive owners and risk managers can take to stay ahead of potential compliance exposures.