Taxation
Proposed Regulations Clarify the BEAT and FATCA
The Department of the Treasury and the Internal Revenue Service issued two sets of proposed regulations that clarify the application of the base-erosion anti-abuse tax (BEAT) and the treatment of insurance premiums under the Foreign Account Tax Compliance Act (FATCA). Eversheds Sutherland explains the proposed regulations and offers key takeaways. Read More
Barbados Repeals Exempted Insurance Act, Captives Maintain Zero Tax
The government of Barbados has announced a number of legislative measures as it moves toward tax convergence of the country's international and domestic business sectors. Captive insurers will maintain zero taxation. Read More
Microsoft's Captive Tax Issues Not Applicable in Most Other States
At the North Carolina captive insurance conference, Bruce Wright, a partner at Eversheds Sutherland (US) LLP, shared some insights surrounding Microsoft Corporation's Arizona captive insurance company (Cypress Insurance Company) payment of more than $875,000 for unpaid premium taxes and interest and penalties to the state of Washington. Read More
A.M. Best Revisits Tax Law Impacts on Captive Insurer Ratings
A.M. Best said that the impact of tax reform is generally a positive for US-domiciled captives and a mixed bag for offshore captive insurance companies, though in some cases, it is a positive for offshore captives that have made the section 953(d) election under the Internal Revenue Code. Read More
Direct Placement Tax Decision from the Tax Court of New Jersey
The Tax Court of New Jersey recently rendered an interesting decision regarding direct placement taxes. Eversheds Sutherland discusses Johnson & Johnson v. Director, Division of Taxation and Commissioner, Department of Banking and Insurance. Read More