Taxation

Swift Becomes 6th Straight IRS Micro-Captive Victory

February 7, 2024

On February 1, Judge Patrick J. Urda continued the Tax Court trend of disallowing deductions for premiums paid to micro-captives in Swift v. Commissioner. Read More


IRS Wins 5th Micro-Captive Insurance Tax Court Case

January 18, 2024

The US Tax Court's latest 831(b) micro-captive decision in Keating determined that the arrangement did not constitute insurance. Read More


US Supreme Court Won't Hear Delaware Appeal in IRS Summons Case

November 27, 2023

The US Supreme Court has declined to consider the Delaware Department of Insurance's appeal of a federal appeals court ruling requiring the department to comply with an Internal Revenue Service (IRS) summons for information on two captive insurers domiciled in the state. Read More


More on IRS Attempts To Subpoena Information Related to Micro-Captives

July 13, 2023

An IRS summons for certain micro-captive information filed with the state of Delaware raises several interesting insurance business questions. Among them is whether some of the documents sought by the IRS can be produced electronically. Read More


Treatment of Certain Voluntary Benefit Payments

July 12, 2023

The Internal Revenue Service (IRS) recently addressed whether benefit payments to employees in a particular welfare benefit plan are includable in gross income. The IRS identified circumstances under which such benefit payments should be treated as wages for federal tax purposes. Read More