Taxation

The US Tax Court ruled in favor of the Internal Revenue Service in a case involving a tribal-domiciled captive insurer. The lack of structured insurance regulation in the Sac and Fox Nation was a notable factor in the court's decision, highlighting the importance of regulatory oversight in selecting a domicile. Read More

Bermuda's new 15 percent corporate tax, effective in 2025, is unlikely to deter its insurance and reinsurance market. The island's established regulatory regime and industry expertise continue to be key attractions for multinational insurers, outweighing concerns about the new tax rate. Read More

The Tax Court's decision in Royal Management v. Commissioner examines an 831(b) insurance arrangement, identifying key issues such as risk shifting, risk distribution, and policy timing. The court found these elements insufficient for the arrangement to qualify as valid insurance for tax purposes, providing insights into the complexities of such cases. Read More

This white paper provides an in-depth look at essential insurance and reinsurance concepts, including risk pooling, exposure units, and the circular flow of funds. Authored by industry experts including Alan Fine from Armanino, it offers practical insights for professionals navigating the complexities of commercial and captive insurance. Read More

Recent court cases and Internal Revenue Service (IRS) regulations are increasing scrutiny on micro-captives, prompting the captive insurance industry to navigate evolving legal and regulatory challenges. Read More