Taxation

The Internal Revenue Service (IRS) finalized regulations on micro-captive insurance, revising criteria for listed transactions and transactions of interest. New disclosure rules affect 831(b) captives, with a 90-day compliance window. Exemptions apply for consumer coverage reinsurance, and a new process allows streamlined revocation of the 831(b) election under Rev. Proc. 2025–3. Read More

The Internal Revenue Service (IRS) and the Treasury Department issued final regulations on micro-captive insurance arrangements, marking an effort to refine the framework for identifying and reporting abusive practices. Read More

Ryan LLC has filed suit against the Internal Revenue Service (IRS), contesting a rule on micro-captive insurance transactions. The firm claims the regulation exceeds authority, disrupts small business risk management, and imposes arbitrary loss ratio thresholds. Read More

This article examines Bermuda's corporate income tax for multinational enterprises, focusing on compliance obligations, economic transition adjustments, and financial impacts. Insights from the Bermuda Captive Conference reveal how the tax aligns with global standards, enhancing transparency and operational predictability for affected entities. Read More

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