The US Tax Court has allowed deductions for insurance premiums paid by affiliated subsidiaries to a captive subsidiary (Rent-A-Center, Inc. and Affiliated Subsidiaries v. Commissioner of Internal Revenue, Docket Nos. 8320-09, 6909-10, 21627-10, 14 January 2014). The case involved a US parent corporation and its approximately 15 affiliated subsidiaries (collectively, the taxpayer) that conducted business through stores owned and operated by the subsidiaries. The parent corporation neither owned stores nor had employees. The taxpayer formed a wholly-owned insurance company (i.e. a captive) in Bermuda to insure the risks relating to the taxpayer's worker's compensation, automobiles, and general liabilities. When the...