30%/60% loss-ratio thresholds
Loss ratio computed quarterly against the bright-line numeric test: below 30% is a listed transaction; below 60% is a transaction of interest. Verified deterministically.
The most rigorous 831(b) compliance file a captive manager can deliver.
ThresholdKeeper assembles a documentation-complete quarterly loss-ratio monitor and annual economic-substance/audit-defense file — every statutory element, every required analysis, the case-law narrative, and the audit-response package — checked against the letter of IRC §831(b) and T.D. 10029 before a credentialed CPA, EA, or tax attorney releases it.
Every subsection of IRC §831(b) and T.D. 1002930%/60% loss-ratio thresholds, gate-checkedCase-law synthesis: Avrahami, Patel, Reserve MechanicalCredentialed signer release on every file5-business-day SLA
Why files fail
A single missing element can trigger penalties up to $200,000.
A small-business 831(b) micro-captive's audit defense is only as strong as the compliance file behind it. Miss the 30% loss-ratio threshold, fail to document economic substance, misapply a circuit split, or skip a quarterly monitor — and the captive can face listed-transaction penalties, accuracy-related penalties, or unwound deductions.
Most captive managers run this by hand, from memory, once a year at best. The regulations have not been read end-to-end since the last audit. That is exactly where compliance gaps hide.
ThresholdKeeper exists to close that gap with a single, exhaustive standard applied identically to every captive.
$200,000
max entity nondisclosure penalty for a listed transaction
The benchmark
Measured against the letter of the statute and regulations — subsection by subsection.
We do not summarize the law and hope. Every file is scored against a versioned rule pack tied to the exact text of IRC §831(b), T.D. 10029, and current case law. These are the provisions each file is held to.
Premium limitation
Annual premium income does not exceed $2.3 million (indexed). Verified against the captive's books.
Diversification requirements
No single policyholder accounts for more than 20% of net written premiums. Checked against the policyholder matrix.
Economic-substance narrative
A client-specific narrative addressing risk distribution, insurance risk, and business purpose, synthesized from the captive's facts and current Tax Court precedent.
Disclosure obligations
Listed transaction and transaction of interest disclosure requirements flagged, with a checklist for Form 8886 filing.
Circuit split tracking
The Texas vacatur and Tennessee upholding of the disclosure regime are tracked and incorporated into the compliance posture analysis.
How a file is built
Intake to credentialed signer release, with deterministic gates the AI cannot overrule.
AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A credentialed CPA, EA, or tax attorney signs every release. That order is never reversed.
01
Compliance Gap Scan
Upload the captive's claims data, premium records, and policyholder list. We return a free completeness read: which thresholds and elements you already have, and which are missing.
02
Data ingestion & validation
As your authorized clerical agent, we ingest structured data from your captive management system and validate loss ratios, premium limits, and diversification against the rule pack.
03
Grounded drafting
The quarterly risk memo and annual economic-substance narrative are drafted from your validated data and the §831(b) rule pack into field-locked templates — no legal opinions, no invented facts.
04
Deterministic completeness gates
Loss ratios reconcile to the claims data to the decimal; premium limits are verified; diversification is checked; disclosure obligations are flagged. Any failure blocks release.
05
Credentialed signer release
A CPA, EA, or tax attorney reviews the exception queue and signs the release. High-value or complex captives route to attorney review first.
06
Delivery
You receive the file: quarterly risk memo, annual economic-substance narrative, evidence log, disclosure checklist, and audit-response package — ready for the captive manager to deliver under its own name.
The bar we hold
Rigor you can measure.
100%
Credentialed-signer released
No file ships without a human CPA, EA, or tax attorney signature.
5 days
Standard SLA
From complete intake to released file.
<1%
Critical-defect target
Tracked against a gold-standard file library.
4
Case-law sources
Avrahami, Reserve Mechanical, Caylor, Patel — every applicable precedent.
Why ThresholdKeeper
Built to be the most thorough option a captive manager has.
Documentation-complete, by design
The deliverable is completeness itself — every statutory element and threshold accounted for or explicitly exception-coded. Nothing is left implicit.
Deterministic, not vibes
The gates that decide completeness are code, not a model's opinion. A drafting error cannot slip past a regulatory requirement.
In its lane, on purpose
We prepare documentation and run analyses as your clerical agent. We never provide legal advice, never contact the IRS on your behalf, and never replace your advisor-client relationship.
Engagement
Flat fee, per captive per year. No hourly billing, ever.
Simple, predictable, and aligned with a compliance standard — not a percentage of any tax savings.
- A free Compliance Gap Scan before you commit — see exactly what is missing.
- One flat fee per captive per year: $6,000–$18,000 depending on complexity; disclosed pass-through data-ingestion fees.
- Optional fixed-fee attorney review for captives with complex structures or active audit exposure.
- Optional Audit-Response Package add-on, assembled within five business days of an IRS notice.
FAQ
Questions, answered precisely.
Is ThresholdKeeper a law firm?
No. ThresholdKeeper, a service of Your Deputy, Obuke LLC, provides documentation-completeness services. It is not a law firm, does not provide legal advice, and does not represent you in any legal matter. Attorney review is available and recommended for captives with active audit exposure.
Do you contact the IRS or file tax returns?
Never. ThresholdKeeper is not a tax preparer and does not file any forms with the IRS. The captive manager or tax advisor remains responsible for all filings and communications with tax authorities.
What makes a file 'complete'?
Completeness is defined by the statute and regulations: the 30%/60% loss-ratio thresholds verified, premium limits checked, diversification confirmed, economic-substance narrative present, disclosure obligations flagged, and circuit split tracked. Deterministic gates enforce each one before release.
How fast is it?
The standard SLA is five business days from complete intake to a credentialed-signer released file. The free Gap Scan is returned much sooner and tells you exactly what is still needed.
How are you priced?
A flat fee per captive per year, plus disclosed pass-through data-ingestion costs. No hourly billing and no percentage of any tax savings or refunds.
See what's missing before it costs you a penalty.
Start with a free Compliance Gap Scan. Send your captive's data and we'll return a completeness read against every subsection of IRC §831(b) and T.D. 10029.
Documentation-completeness service · not legal advice · the captive manager delivers every file.