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EAD applications include the assessment of internal risk distribution through a substantial number of statistically independent risk units as described in Avrahami v. Commissioner of Internal Revenue and other U.S. Tax Court rulings. A generally-accepted actuarial approach to quantifying internal risk distribution may provide a method for more captive insurance companies to satisfy the risk distribution requirements of bona fide insurance without accessing a reinsurance pool.
Derek W. Freihaut
FCAS, MAAA Principal and Consulting Actuary
Robert J. Walling III
FCAS, MAAA, CERA Principal and Consulting Actuary
Christopher M. Holt
ACAS, MAAA Consulting Actuary
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