"[Rev. Rul. 2014-15] is significant for employers considering a captive reinsurance arrangement to manage risk with respect to employee benefits because the ruling provides the IRS' first published support in more than two decades for the position first stated in Revenue Ruling 92-93 that an employer that insures (or reinsures) its employee benefit risks is not self-insuring the risks because the economic risk of loss being insured is that of the employees, not the employer's. The Revenue Ruling also demonstrates that this same position applies to retiree benefits as well as active employee benefits."

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