Taxation
Tax Reform: Best Briefing on Insurer Benefits and Partial Offsets
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. Read More
Bermuda Delineates Fact from Fiction in Answering ICIJ Reports
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. Read More
Eversheds Sutherland Observations on the Unified Tax Framework
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. Read More
A Checklist for 831(b) Captives in Light of the Avrahami Tax Case
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. Read More
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). Read More