Taxation

Eversheds Sutherland Observations on the Unified Tax Framework

October 4, 2017

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

September 27, 2017

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

August 22, 2017

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


"Insurance Risk" Defined by IRS

March 7, 2016

Internal Revenue Service ruling specifies types of coverage that do not qualify as insurance risk for determining tax-deductibility of premiums paid to a captive insurer. Read More


US Tax Court: Securitas a Bona Fide Captive Insurance Arrangement

October 30, 2014

US companies are entitled to premium and interest expense deductions if a captive is created for business purposes, an opinion of the US Tax Court has determined. Read More