Taxation

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


Microsoft's Captive Tax Issues Not Applicable in Most Other States

August 23, 2018

At the North Carolina captive insurance conference, Bruce Wright, a partner at Eversheds Sutherland (US) LLP, shared some insights surrounding Microsoft Corporation's Arizona captive insurance company (Cypress Insurance Company) payment of more than $875,000 for unpaid premium taxes and interest and penalties to the state of Washington. Read More


A.M. Best Revisits Tax Law Impacts on Captive Insurer Ratings

June 29, 2018

A.M. Best said that the impact of tax reform is generally a positive for US-domiciled captives and a mixed bag for offshore captive insurance companies, though in some cases, it is a positive for offshore captives that have made the section 953(d) election under the Internal Revenue Code. Read More