In an article published in FC&S Legal on May 15, 2018, attorneys Phil Karter, J. Scot Kirkpatrick and Christopher A. Steele address recent developments in the small captive insurance industry. The article states that “taxpayers’ take-away from Congress’ continued support for small captives should be that while Avrahami may represent a ‘what not to do’ roadmap for setting up and running a small captive, it should not deter taxpayers from taking advantage of the benefits small captive insurance companies can provide in effective risk minimization.”