Blake Kerr, partner and CFO at Helio, said the company has been helping firms restructure small captives or wind down some that are making the 831(b) election and looking at the best steps legally do so.

“We then take a ‘start fresh’ approach with a new captive, reapproaching the risk profile in a way that is less controversial for the IRS at this time,” he said.

Kerr said it is an “absolute fact” that national and super regional accounting firms and law firms are distancing themselves from anything related to 831(b) captives.