IRS Chief Counsel Memorandum Confirms IRS Position Concerning Offshore Micro-Captives

September 16, 2021

Although it should come as no surprise, in CCM 202134017, the Internal Revenue Service (IRS) has made clear its position regarding micro-captives formed in a jurisdiction outside the United States. Read More

Washington State Issues Regulations Implementing New Captive Tax Law

August 24, 2021

The Office of the Insurance Commissioner for Washington State has issued draft regulations to implement legislation state lawmakers passed in April that sets new requirements for captive insurance companies licensed in other domiciles but doing business in the state of Washington. Washington State insurance regulators described the new law as a fair compromise. Read More

Bermuda Joins OECD "Inclusive Framework" on Global Taxation Plan

July 9, 2021

The government of Bermuda has joined the Organization for Economic Cooperation and Development's (OECD) "Inclusive Framework" for international taxation. A statement said Bermuda officials look forward to supporting the OECD's ongoing technical discussions ahead of the G20 foreign ministers' meeting in October 2021. Read More

Abusive Micro-Captive Arrangements Return to IRS "Dirty Dozen" List

July 8, 2021

After a year's absence, abusive micro-captive arrangements have returned to the US Internal Revenue Service's (IRS) annual "Dirty Dozen" list of "tax scams." The IRS had left micro-captives off its 2020 Dirty Dozen list, the first time in 5 years they weren't included. Read More

High Court Rules for CIC Services in IRS Micro-Captive Reporting Case

May 19, 2021

In a unanimous ruling, the US Supreme Court held that captive manager CIC Services' challenge of an Internal Revenue Service (IRS) micro-captive reporting requirement is not prohibited by federal law. In its ruling, the high court overturned a federal district court ruling and remanded the case to the lower court. Read More