Syzygy Captive Not in the Business of Insurance, According to Tax Court

April 18, 2019

In Syzygy Ins. Co. v. Commissioner, T.C. Memo 2019-34, the Tax Court considered yet another case involving a company that had elected to be taxed under section 831(b) of the Internal Revenue Code of 1986. Read More

Bermuda Included in EU Tax Blacklist in "Error"

March 15, 2019

The European Union has updated its list of noncooperative tax jurisdictions. The so-called blacklist document identifies 15 countries for failing to meet agreed good tax governance standards. This year's list includes Bermuda, the world's largest captive domicile. Read More

Captive Insurance and State and Local Income Tax Issues

February 11, 2019

According to Bruce Wright of Eversheds Sutherland, state and local income taxes are an evolving issue that concerns captive insurers. He says some states are challenging whether a captive insurer's income should be included with combined income when determining the overall income tax of the parent. Read More

Proposed Regulations Clarify the BEAT and FATCA

January 16, 2019

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

November 21, 2018

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