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Legal Alert: Final Rules on Compensation Deduction Limit for Health Insurers

The Internal Revenue Service (IRS) and the Department of Treasury (Treasury) have issued final regulations under section 162(m)(6) of the Internal Revenue Code of 1986, as amended (Code), which limit the deduction certain...more

9/26/2014 - Compensation & Benefits Healthcare Independent Contractors IRS U.S. Treasury

Required Summer Reading: Guidance Issued on the Tax Treatment of Guaranteed Minimum Benefit Hedges and Identified Mixed Straddles

The Treasury and the IRS offered two pieces of highly anticipated guidance on July 18 that are particularly relevant to the life insurance industry. ...more

7/24/2014 - Bonds Capital Losses Corporate Bonds Federal Taxes Final Guidance Hedges Insurers IRC IRS Mixed Straddle U.S. Treasury Variable Annuities

After All the Preparation, It’s Finally Here: FATCA Becomes Effective July 1, 2014

More than four years after Congress enacted the Hiring Incentives to Restore Employment Act of 2010, Pub. L. 111-147, which added the Foreign Account Tax Compliance Act (FATCA) provisions to the Internal Revenue Code, FATCA...more

7/1/2014 - FATCA FFI Form W-8 Intergovernmental Agreements IRS U.S. Treasury

Whose Risk Is It Anyway? New Revenue Ruling Provides Guidance for Employee Benefits Captives

On May 8, the IRS issued Rev. Rul. 2014-15, 2014-22 I.R.B. 1, which provides guidance in the rapidly expanding area of insuring or reinsuring employee benefits with captives. ...more

5/16/2014 - Affordable Care Act Captive Insurance Company Employee Benefits ERISA IRS Reinsurance

To the Direct Acquirer Belong the Tax Attributes: Proposed Regulations Modify the Definition of Acquiring Corporation for Purposes...

On May 7, Treasury and the IRS published proposed regulations addressing which corporation succeeds to the tax attributes of another corporation that transfers assets in an acquisitive asset reorganization described in IRC §§...more

5/13/2014 - Acquisitions Asset Transfer Business Assets IRC IRS Proposed Regulation Reorganizations Section 381 Subsidiaries U.S. Treasury

IRS Declares 2014 and 2015 as a Transition Period for FATCA Administration and Enforcement and Provides an Additional Six Months...

Pursuant to Notice 2014-33 (the Notice), the IRS announced that it will treat calendar years 2014 and 2015 as a transition period for the administration and enforcement of the due diligence, reporting, and withholding...more

5/9/2014 - Due Diligence Enforcement Extensions FATCA FFI IRS

FY 2015 Budget Tax Proposals Target Insurance Companies

On March 4, the Obama Administration released its fiscal year 2015 budget (FY 2015 Budget). In keeping with the Administration’s past budgets, the FY 2015 Budget includes a number of tax proposals that target insurance...more

3/6/2014 - Corporate Taxes FATCA Federal Budget Insurers Tax Liability Tax Reform

Potential Impact of the Tax Reform Act of 2014 on Insurance Companies

On February 26, House Ways and Means Committee Chairman Dave Camp (R-Mich.) released a “Discussion Draft” of the Tax Reform Act of 2014, which sets forth his much-anticipated tax reform proposals. Of note, the Discussion...more

3/3/2014 - Business Taxes Corporate Taxes Life Insurance Tax Reform

New FATCA Regulations Address Certain Concerns of the Insurance Industry

On February 20, Treasury and the IRS issued new final and temporary Foreign Account Tax Compliance Act (FATCA) regulations. In brief, the new FATCA regulations provide positive changes with respect to several issues raised...more

3/3/2014 - FATCA FFI IRS

IRS Signals a Potential End to Its Administrative Pursuit of the Separate Account DRD

On February 4, the IRS issued a new revenue ruling – Rev. Rul. 2014-7 – that indicates that the IRS no longer plans to issue formal guidance concerning the treatment of the dividends-received deduction (DRD) with respect to...more

2/13/2014 - Dividends Income Taxes IRS Life Insurance Tax Deductions

Victory for the Taxpayer in Validus: District Court Holds that Federal Excise Tax Does Not Apply to Retrocessions

On February 5, the U.S. District Court for the District of Columbia issued its opinion in Validus Reinsurance, Ltd. v. United States, which is the first case to involve a challenge to the IRS’s position on the “cascading”...more

2/7/2014 - Excise Tax Federal Taxes IRS Retrocessional Claims

Leaving a Legacy: Divided Tax Court Allows Deductions for Insurance Premiums Paid to Captive Insurance Affiliate

On January 14, the United States Tax Court issued a reviewed opinion in Rent-A-Center Inc. v. Commissioner, 142 T.C. 1 (2014), which held that subsidiaries of Rent-A-Center Inc. (RAC) were entitled to claim deductions for...more

1/20/2014

Legal Alert: New Extended FATCA Implementation Dates

On July 12, 2013, the IRS, in Notice 2013-43, and the Department of the Treasury in a Press Release of the same date, extended the implementation dates by six months for many of the withholding and account due diligence...more

7/16/2013 - Deadlines Delays FATCA FFI Foreign Jurisdictions IGAs Internal Revenue Code IRS U.S. Treasury

Legal Alert: The End of an Era: IRS Expands “No-Rule” Policy for Spin-Offs and Other Common Corporate Transactions

On June 25, the IRS expanded its “no-rule” policy with respect to spin-offs and other tax-free corporate separations, liquidations, contributions, and reorganizations. Effective for letter ruling requests received by the IRS...more

6/27/2013 - Integrated Transactions IRS Liquidation No-Rule Policy Spinoffs

At Last: Final Regulations Issued Under Section 336(e)

In a move that was nearly 27 years in the making, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued long-awaited final regulations under §336(e) (the Final Regulations) on May 10. Section 336(e)...more

5/14/2013 - Corporate Taxes Distribution Rules IRS Proposed Regulation Stocks

Legal Alert: FATCA NFFE Rules Subject Non-U.S. P&C Insurers and Reinsurers to Burdensome Reporting Requirements

The good news is that, under the recently released Foreign Account Tax Compliance Act (FATCA) regulations, most non-U.S. property and casualty (P&C) insurance and reinsurance companies will not be considered foreign financial...more

5/6/2013 - FATCA FFI Non-Financial Firms Reinsurance Reporting Requirements

Proposed Legislation Would Sweep Certain Offshore Corporations into the U.S. Tax Net and Subject Their Worldwide Income to U.S....

The Stop Tax Haven Abuse Act and the International Tax Competitiveness Act of 2013 are two parts of a package of three bills introduced in the U.S. House of Representatives on April 15 by Rep. Lloyd Doggett. A significant...more

4/25/2013 - Foreign Corporations International Tax Competitiveness Act of 2013 International Tax Issues Offshore Companies Proposed Legislation Stop Tax Haven Abuse Act Tax Haven

Legal Alert: New Budget Proposals Once Again Target Insurance Companies

On April 10, the Obama Administration released its fiscal year 2014 budget (FY 2014 Budget). Of note, the FY 2014 Budget includes a number of tax proposals that target insurance companies or that otherwise would have a direct...more

4/16/2013 - Barack Obama Dividends FATCA Federal Budget Financial Crisis Responsibility Fee Life Insurance Private Separate Accounts Reinsurance Reporting Requirements Tax Deductions

Legal Alert: IRS Proposes Rules on Health Insurer Fee

The Internal Revenue Service (IRS) has released proposed regulations on the health insurer fee under section 9010 of the Patient Protection and Affordable Care Act (PPACA). The regulations, which were published in the Federal...more

3/14/2013 - Affordable Care Act Fees Healthcare HI Tax Insurers IRS Reporting Requirements Tax Assessment

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