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.
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.
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.
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.
The Tax Court of New Jersey recently rendered an interesting decision regarding direct placement taxes. Eversheds Sutherland discusses Johnson & Johnson v. Director, Division of Taxation and Commissioner, Department of Banking and Insurance.