News & Analysis as of

Retrocession Contracts

Carlton Fields

Court Confirms Arbitration Award In Reinsurance Dispute Involving Quota Share Retrocessional Agreement

Carlton Fields on

A court confirmed a final arbitration award in favor of Continental Insurance Company (as successor by merger to Continental Reinsurance Corporation) and against AXA Versicherung AG. Continental Re was a reinsurer of...more

Locke Lord LLP

Validus Round Two: Court of Appeals’ Decision Holding That Wholly-Foreign Retrocessions Are Not Subject to Federal Excise Tax...

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On May 26, 2015, the United States Court of Appeals for the District of Columbia upheld a District Court decision and ruled that the Internal Revenue Service could not impose excise tax on certain wholly-foreign retrocessions...more

Morrison & Foerster LLP

MoFo Tax Talk - Volume 8, Issue 2

IRS Releases Notices Designating Certain “Basket Contracts” As Listed Transactions And Others As Reportable Transactions Of Interest - On Wednesday, July 8, the IRS released two notices addressing “basket contracts,”...more

Carlton Fields

D.C. Circuit Holds That Wholly Foreign Retrocessions Not Subject To U.S. Excise Tax

Carlton Fields on

In late May, the United States Court of Appeals for the District of Columbia Circuit affirmed a grant of summary judgment to a reinsurer in a dispute with the IRS regarding the imposition of U.S. excise taxes on a wholly...more

Eversheds Sutherland (US) LLP

Validus Affirmed for All the Right Reasons – The FET Does Not Apply to Wholly Foreign Reinsurance Transactions

On May 26, the U.S. Court of Appeals for the District of Columbia affirmed the result of the U.S. District Court for the District of Columbia in Validus Reinsurance, Ltd. v. U.S., 19 F. Supp. 3d 225 (2014), which was the...more

Locke Lord LLP

Locke Lord QuickStudy: Validus Court of Appeals Decision - Wholly-Foreign Retrocessions Not Subject to Federal Excise Tax

Locke Lord LLP on

On May 26, 2015, the United States Court of Appeals for the District of Columbia upheld a District Court decision and ruled that the Internal Revenue Service could not impose excise tax on certain wholly-foreign retrocessions...more

Locke Lord LLP

Validus Wins Round Two: Wholly-Foreign Retrocessions Not Subject to Federal Excise Tax

Locke Lord LLP on

On May 26, 2015, the United States Court of Appeals for the District of Columbia upheld a lower court decision and ruled that the IRS could not impose excise tax on certain wholly-foreign retrocessions of insurance. The...more

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