On February 17, 2023, the Department of Treasury (Treasury) and the Internal Revenue Service (the IRS) issued Notice 2023-20 (the Notice), to provide guidance that is intended to help avoid unintended adverse consequences to...more
The Internal Revenue Service (IRS) and the Treasury Department (Treasury) have issued final regulations that address amendments to the rules for discounting unpaid losses pursuant to Section 846 under the Tax Cuts and Jobs...more
6/25/2019
/ Corporate Bonds ,
Corporate Taxes ,
Discounts ,
Final Rules ,
Interest Rates ,
Internal Revenue Code (IRC) ,
IRS ,
NAIC ,
Net Operating Losses ,
Tax Cuts and Jobs Act ,
U.S. Treasury
On April 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced three new compliance campaigns. The campaigns focus on:
..Transfer pricing for “captive” services...more
4/29/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
FATCA ,
Filing Requirements ,
Internal Revenue Code (IRC) ,
IRS ,
Large Business & International Division (LB&I) ,
OECD ,
Offshore Banks ,
OVDP ,
Related Parties ,
Transfer Pricing
On December 13, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued two sets of proposed regulations of importance to insurance companies. One set was the long-awaited regulations...more
12/21/2018
/ Banks ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
Broker-Dealer ,
Corporate Taxes ,
FATCA ,
Insurance Industry ,
IRS ,
Proposed Regulation ,
Tax Cuts and Jobs Act ,
Tax Rates ,
U.S. Treasury
On December 13, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations under section 59A of the Internal Revenue Code of 1986, as amended, commonly referred to as...more
On September 21, the United States Tax Court held in favor of the taxpayer in R.V.I. Guaranty Co., Ltd. and Subsidiaries v. Commissioner, 145 T.C. No. 9 (2015). The court concluded that the residual value insurance policies...more
On February 2, the Obama Administration released its fiscal year 2016 budget (FY 2016 Budget). The hallmarks of the FY 2016 Budget are proposals that would impose (i) a minimum tax on the current foreign earnings of U.S....more
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
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