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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

Carlton Fields

New Jersey Tax Court Finds That Companies For Which New Jersey Is The Home State Must Pay Taxes On All Premiums Paid To Captive...

Carlton Fields on

A tax court judge in New Jersey has handed Johnson & Johnson (J&J), and likely other New Jersey-based businesses that operate captive insurers, a significant loss in an opinion interpreting the federal Nonadmitted and...more

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