About Us: Zerbe, Miller, Fingeret, Frank & Jadav is one of the nation’s most experienced law firms handling captive insurance audit defense and compliance. Representation of captive insurance company owners and service providers nationwide gives ZMFF&J a coordinated perspective on the issues and concerns regularly raised by the IRS in their examinations of taxpayers on this issue. IRS scrutiny of captive insurance gained substantial momentum in early 2014 as The Service launched a series of 6700 promoter examinations aimed at multiple captive management firms. In short order, these examinations led to informal documentation requests, and audits of captive insurance company owners nationwide. By 2015, The IRS listed captives on its Dirty Dozen List acknowledging that captives were legal when done properly, but including captive insurance among potential “tax scams,” along with identity theft, phishing, preparer fraud and offshore tax avoidance.