concern is the premium. Each Delaware captive has a $$2,000,000$ premium, costing them a total of $$8,000,000.$ In order to qualify for tax exemption, the premium cap is $$2\mathrm{.}85$ million. HealthToYou has a captive for each individual non$-$traditional risk, including reputation damage, violation of HIPPA, employment practices liability, and excess cyber. While the Delaware captives are not meeting the premium cap, they are awfully close which could raise red flags with the IRS. Given that in total the four captives premium exceed the premium cap for an $831($b$)$ captive insurance company this set up could be viewed as a way for HealthToYou to get around legislation making it appear that they are only operating for tax advantages and are not a true insurance option.