"In order for an arrangement to qualify as insurance, the arrangement must, among other requirements, shift the risk of loss from the party paying the premium to the recipient of the premium, and the recipient must distribute that risk of loss among other insured parties. Prior to the issuance of Revenue Ruling 2014-15, there was uncertainty as to whether retiree health benefits funded through captive insurance subsidiaries had sufficient risk shifting and risk distribution to qualify as insurance."  MORE >>