Finance, Investments, and Accounting
While the US Tax Court's "Avrahami" decision qualifies as a taxpayer loss, Tom Jones of McDermott Will & Emery finds positive elements to the decision. He says along the larger continuum of tax concerns relating to captives, the decision provides further clarity and should benefit larger captives.
Much has been shared, and many lessons can be learned from "Avrahami v. Comm'r" and "Feedback Ins. Co., Ltd. v. Comm'r," 149 T.C. 7 (2017). Jeremy and Richard Colombik provide their take on the lessons learned from the case.
For captives, especially smaller captives or group captives, passive investing can help reduce frictional investment expenses in a low yield, total return environment. A recent S&P webinar and "Wall Street Journal" article strengthen the argument for passive investing, thereby reinforcing a case for captives' use of passive investing.
A review of the reported financial results of risk retention groups reveals insurers that continue to collectively provide specialized coverage to their insureds while remaining financially stable, according to the latest Demotech report on the sector. While risk retention groups have reported net income, they have also continued to maintain adequate loss reserves while increasing premium written year over year.
Today's financial news headlines are filled with stories about the rise of passive investing as investors abandon active managers. Those who own captive insurers or who oversee management of their portfolios should understand the active versus passive management debate and why active investment management, at least for fixed income portfolios, often makes sense. Active management needs to evolve, but it will survive.