Taxation

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

Internal Revenue Service (IRS) audit guidance indicates withholding tax on micro-captive premiums, following the "Reserve Mechanical" ruling, which voided tax exemptions under IRC section 953(d) and 501(c)(15). Read More

Iowa lowers reinsurance tax rates for captives with HF 2636, offering competitive rates and enhancing the state's appeal for captive insurers. Read More