Facts:  Client forms irrevocable trust for the benefit of his children with a non adverse party as trustee.  Client gifts cash to trust and trustee uses the cash to form a captive insurance company that insures client's business.

Client is President and a member of the board of insurance company, presumably entitled to reasonalbe compensation and at least partially in charge of whether dividends are ever declared.  Key employees of client's business are also officers and directors and with client make up a majority of the directors.

Does client's involvement with the operation of captive insurance company cause its value to be included in client's estate for federal estate tax purposes?

Thank you.