Following the passage of the Tax Cuts and Jobs Act by the US Congress, Captive.com met with Bruce Wright of Eversheds Sutherland to document his take on the primary impacts of the tax law on the captive insurance industry. According to Mr. Wright, a number of the law's provisions may affect captives.
According to A.M. Best, the insurance industry will see overall benefits from the reduced corporate tax rate as a result of the Tax Cuts and Jobs Act once it is signed into law; however, partially offsetting the benefits are certain revenue enhancements that will impact companies.
Recent reports from the International Consortium of Investigative Journalists (ICIJ) expose the names of people and companies behind what it alleges are "secret offshore structures" that, in some cases, are used to reduce or avoid taxes. Bermuda has responded to the ICIJ reports to delineate fact from fiction.
Eversheds Sutherland provides its observations on the Republican unified tax framework. The framework is intended to serve as a "template" for the tax-writing committees, the House Ways and Means Committee, and the Senate Finance Committee to draft tax reform legislation.
This 5-part checklist lays out a set of fundamental policies and practices 831(b) captives should follow. While the Avrahami 831(b) captive tax case may have been unique, owners need to be following essential protocols. In doing so, they are much less likely to find themselves the subject of an IRS audit.