News & Analysis as of

Tax Liability Insurance Industry

Lewis Roca

Supreme Court Decision in Connelly v. United States

Lewis Roca on

On June 6, 2024, the United States Supreme Court issued its decision in in Connelly, As Executor of the Estate of Connelly v. United States, (602 US ________). The decision involves the application of the federal estate tax...more

Woodruff Sawyer

Tax Liability Insurance: Overview & 2024 Market Update

Woodruff Sawyer on

Nearly all carriers will list the above exclusions; however, some may also exclude Fraud and Settlement without Consent from coverage. As with RWI, Tax Liability Policies are non-renewable. They have a one-time premium...more

McDermott Will & Emery

Weekly IRS Roundup January 3 – January 6, 2023

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 3, 2023 – January 6, 2023...more

Lowenstein Sandler LLP

Tax Liability Insurance Products: A Hidden Gem in the Transactional Lawyer’s Tool Box

Lowenstein Sandler LLP on

In this episode of “Don't Take No for an Answer,” Lynda A. Bennett talks with Justin Berutich and Yoav J. Shans about why more companies don’t take advantage of tax liability insurance, how tax products may be used as an...more

McDermott Will & Emery

Weekly IRS Roundup November 22 – November 26, 2021

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 22, 2021 – November 26, 2021... November 22, 2021: The IRS released a memorandum...more

Carlton Fields

New Jersey Supreme Court Affirms $56M Refund to Johnson & Johnson for Overpayment of Insurance Premium Tax

Carlton Fields on

The New Jersey Supreme Court recently ruled that Johnson & Johnson is required to pay an insurance premium tax (IPT) based only on its premiums for risks located within the state of New Jersey rather than nationwide,...more

Gerald Nowotny - Law Office of Gerald R....

PRIVATE PLACEMENT LIFE INSURANCE WEBINAR

Discussion Points: a. Why financial advisors and life insurance agents should be selling PPLI now. b. An overview of the current lay of the land in PPLI. c. The important tax rules of PPLI. d. Planning examples using...more

Farrell Fritz, P.C.

Insured To Captive: “More, Charge Me More, Charge Me More . . .” Premiums?*

Farrell Fritz, P.C. on

It’s Not All About 2017- A casual review of the recent tax literature may leave a “lay person” with the impression that, prior to the passage of the 2017 tax legislation, tax advisers had nothing else to write about....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

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

Plaintiffs’ Notice That the ‘Taxman Cometh’ Was Sufficient to Trigger Statute of Limitations

Carlton Fields on

In a November 16, 2017 ruling, a California appellate court affirmed a summary judgment ruling in favor of several financial advisors, and insurer American General Life Insurance Company, holding that plaintiffs’ fraud and...more

Mintz - Privacy & Cybersecurity Viewpoints

Five Questions for Investors in Insurtech

Decisions you make when founding and/or investing in an insurtech venture can dictate your regulatory obligations, tax liability, operational structure and, ultimately, profitability. Here are five seemingly simple...more

Troutman Pepper

New York State Denies Taxpayer's Insurance (Deduction) Claim - Tax Update Volume 2016, Issue 1

Troutman Pepper on

Captive insurance arrangements, in New York and in certain other states, are often dependent on the federal treatment of the relationship as insurance for federal income tax purposes. A recent New York state...more

Eversheds Sutherland (US) LLP

FY 2015 Budget Tax Proposals Target Insurance Companies

On March 4, the Obama Administration released its fiscal year 2015 budget (FY 2015 Budget). In keeping with the Administration’s past budgets, the FY 2015 Budget includes a number of tax proposals that target insurance...more

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