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Captive Insurance Company Internal Revenue Service Tax Court

Latham & Watkins LLP

Tax Court to Consider Relevancy Threshold for Economic Substance Doctrine Under Section 7701(o)

Latham & Watkins LLP on

The Tax Court has invited amicus briefs and will address the codified meaning of the economic substance doctrine after increased IRS use of the doctrine to challenge taxpayer transactions. In a July 19, 2024, order in...more

Farrell Fritz, P.C.

How Dealings Between Related Parties Doomed A Captive Insurer

Farrell Fritz, P.C. on

Insurance: What is it? How does it work? Assume that Acme Co is paying premiums for commercial insurance coverage to protect itself from economic losses that may arise out of various events. These premiums are deductible...more

Downs Rachlin Martin PLLC

Captive Insurance Update | Spring Edition | 2019: A summary of state and federal developments in the captive insurance industry

There were no significant changes in Vermont’s leadership team during the last election cycle. Governor Phil Scott, a Republican, was re-elected in November 2018 for another two-year term. Michael Pieciak, the Commissioner of...more

Carlton Fields

U.S. Tax Court Finds Captive Insurer Is Not an “Insurance Company” Under the Internal Revenue Code

Carlton Fields on

In this case, Reserve Mechanical Corp. (“Reserve”), a captive insurer incorporated under the laws of Anguilla, sued the Commissioner of Internal Revenue in the U.S. Tax Court regarding the Commissioner’s findings of $477,261...more

Carlton Fields

Tax Court Disallows Deductions For Payments To Captive Insurance Company

Carlton Fields on

A husband and wife who paid $1.54 million in premiums to their captive insurance company and $720,000 in premiums to another insurer over two years, almost all of which ended up back in their bank accounts, have had their tax...more

Holland & Knight LLP

Takeaways from the Tax Court's First Micro-Captive Insurance Ruling

Holland & Knight LLP on

• The U.S. Tax Court recently ruled in Avrahami v. Commissioner, the first litigated Tax Court case involving an 831(b) captive insurance company. • The Tax Court held that two of the key factors that define "insurance"...more

Fox Rothschild LLP

Tax Court Issues Opinion Striking Down Captive Insurance Arrangement

Fox Rothschild LLP on

The Tax Court has issued its long-awaited decision addressing captive insurance arrangements. In Avrahami v. Commissioner, 149 T.C. No. 7 (2017), the Tax Court held that payments made from a number of businesses owned by the...more

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