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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

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

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: 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

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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