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  • Tom Jones Finds Taxpayer-Positive Interpretation of "Avrahami" Decision 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.
  • Lessons Learned from the "Avrahami" Case 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.
  • Court Concludes Tax Elections Invalid in Avrahami and Feedback Decision On August 21, 2017, the US Tax Court decided two companion cases, Avrahami v. Commissioner and Feedback Insurance Company, Ltd., v. Commissioner, 149 T.C. No. 7, which involved issues around the formation and operation of a captive in Saint Kitts and elections under Internal Revenue Code sections 953(d) and 831(b).
  • What Are the Financial Benefits of a Deductible Reimbursement Policy? An operating company may achieve immediate financial benefits by using a captive insurer to issue a deductible reimbursement policy for its high deductible retentions. The tax implications for reimbursement policies for high deductibles are explained in this video by Martin Eveleigh of Atlas Insurance Management.
  • IRA Tax Ruling Favors Captive Insurance Management Services International (MSI) recently analyzed the "Summa Holdings, Inc. v. Comm'r" case decided and filed in February. In its analysis, MSI asks us to consider if this individual retirement account (IRA) tax ruling has favorable implications for the captive insurance industry and moves to the conclusion that the answer is affirmative.
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  Golden scales of justice in front of an American flag with yellow fringe

Tom Jones Finds Taxpayer-Positive Interpretation of "Avrahami" Decision

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.
August 31, 2017 Read More
  Gavel and Tax Blocks-SF

Lessons Learned from the "Avrahami" Case

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.
August 30, 2017 Read More
  tax wooden blocks with gavel SF

Court Concludes Tax Elections Invalid in Avrahami and Feedback Decision

On August 21, 2017, the US Tax Court decided two companion cases, Avrahami v. Commissioner and Feedback Insurance Company, Ltd., v. Commissioner, 149 T.C. No. 7, which involved issues around the formation and operation of a captive in Saint Kitts and elections under Internal Revenue Code sections 953(d) and 831(b).
August 22, 2017 Read More
  Martin Eveleigh

What Are the Financial Benefits of a Deductible Reimbursement Policy?

An operating company may achieve immediate financial benefits by using a captive insurer to issue a deductible reimbursement policy for its high deductible retentions. The tax implications for reimbursement policies for high deductibles are explained in this video by Martin Eveleigh of Atlas Insurance Management.
August 09, 2017 Read More
  Gavel and Dollars-SF

IRA Tax Ruling Favors Captive Insurance

Management Services International (MSI) recently analyzed the "Summa Holdings, Inc. v. Comm'r" case decided and filed in February. In its analysis, MSI asks us to consider if this individual retirement account (IRA) tax ruling has favorable implications for the captive insurance industry and moves to the conclusion that the answer is affirmative.
June 26, 2017 Read More
  Tax Calculator and Pen SF

What Is a Reciprocal Insurance Company, and How Is It Taxed?

A reciprocal insurance company is an arrangement through which mutual promises of the participants are exchanged with respect to their insurance risks. While not a separately incorporated company, it is characterized as an insurance company for federal tax purposes.
March 01, 2017 Read More
  Tax Laws-SF

Direct Procurement Taxes: A Primer for Captives

Direct procurement taxes, also known as self-procurement taxes, are imposed by many states when an insured purchases insurance from an insurer not licensed in the state. These taxes can drive up the cost associated with buying insurance from a captive. This article is a primer on direct procurement taxes and how they operate.
February 22, 2017 Read More
  IRS Dirty Dozen-SF

Captives Once Again Make the IRS "Dirty Dozen" List

For the third consecutive year, what it calls "abusive micro-captives" make an appearance on the IRS's annual "Dirty Dozen" list of tax scams in 2017. This article points out some important distinctions in the messaging around the IRS's 2017 announcement as compared to last year.
February 20, 2017 Read More
  Tax Building Blocks-SF

The Basics of the 831(b) Election for Captives

Section 831(b) of the Internal Revenue Code may be elected by qualifying captives to exempt the captive insurer's underwriting profits from federal income tax. This article discusses the prerequisites that must be met as well as the transactions of interest reporting requirements.
January 25, 2017 Read More
  Accounts Filing Forms-SF

What Is FATCA, and How Do Captives Handle It?

This article discusses the Foreign Account Tax Compliance Act (FATCA) and how FATCA's requirements affect captives. FATCA's provisions operate to encourage compliance with US information reporting requirements by imposing a withholding tax on those that fail to comply.
January 18, 2017 Read More
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