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IRS Dirty Dozen Abusive Tax Structures Single Out Micro-Captives

In IR-2015-19, the IRS explained that 831(b) micro-captives may be considered abusive tax structures and outlined determining criteria.
February 06, 2015 Read More
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NY Times Reports on Life Insurer Tax Avoidance through Use of Captives

The New York Times has reported that life insurers are …”taking advantage of fierce competition for their business among states, which have passed special laws that allow the companies to pull cash away from reserves they are required to keep to pay claims.”
December 15, 2014 Read More
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U.S. Tax Court: Securitas a Bona Fide Captive Insurance Arrangement

U.S. companies are entitled to premium and interest expense deductions if a captive is created for business purposes, an opinion of the U.S. Tax Court has determined.
October 30, 2014 Read More

CICA Webinar Looks at Base Erosion and Profit Shifting (BEPS)

The Organization for Economic Cooperation and Development (OECD) plan for tax base erosion and profit shifting is already affecting corporations, even though implementing the recommendations will be challenging, according to the speakers at last week’s Captive Insurance Companies Association (CICA) seminar on transfer pricing.
October 21, 2014 Read More
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Base Erosion and Profit Shifting by Multi-national Corporations (BEPS)

The Organization for Economic Cooperation and Development's (OECD) and G20 are working to eradicate base erosion and profit shifting (BEPS) by multinational corporations. This will undoubtedly impact offshore captive domiciles.
September 30, 2014 Read More
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Captives Land on IRS Priority Guidance Plan for 2014–2015

On August 26, 2014, the Internal Revenue Service issued its Priority Guidance Plan (PGP) for 2014–2015. The list reflects 317 projects the IRS designates as priorities for the allocation of resources during the designated period, although generally not all items are completed during the designated period.
September 25, 2014 Read More
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Trial Held in RVI Case

Beginning on September 2, a 3-day trial was held at the U.S. Tax Court in the case of RVI Guaranty Co. Ltd. and Subsidiaries v. Commissioner. The issue in the case is whether residual value insurance, which insures lessors against an unexpected loss in the value of property they lease, qualifies as insurance for federal tax purposes.
September 25, 2014 Read More