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Rebuilding After Hurricanes Harvey and Irma: Recovery Through Tax Deductions

by Bowditch & Dewey on

It is estimated that less than 20% of those affected by Hurricane Harvey, and a week later Hurricane Irma, had flood insurance. Home owner’s and renter’s insurance policies exclude damage caused by floods. Those affected...more

Client Alert: Avrahami v. Commissioner: An Important Ruling on Microcaptive Structures

While many were captivated by the solar eclipse on August 21st, the US Tax Court, in Avrahami v. Commissioner, shed judicial light on the tax treatment of what is known as a “microcaptive” insurance company. More...more

Court Upholds Attorney-Client Privilege Despite Advice Of Counsel Defense In Tax Case Involving Reinsurance Transaction

by Carlton Fields on

This case involves a tax dispute centering on whether certain “purported” insurance and reinsurance transactions “lacked economic substance.” Following an in camera review of communications identified in Respondents’...more

Securitisation in Poland: Legal and tax aspects

by Hogan Lovells on

Securitisation transactions have been receiving increased attention as attractive alternatives for Polish companies, especially those who can derive large pools of receivables from the debtors which are consumers or...more

Captive Insurance Update | Issue No. 1 | 2017 - A summary of state and federal developments in the captive insurance industry

Changes at the Top - Republican Phil Scott was elected Governor of Vermont in November 2016, having previously served as Lieutenant Governor for six years. Governor Scott has re-appointed Michael Pieciak to serve as the...more

Insurance Proceeds Payable To Tenant Diverted To Pay For Property Owner's Back Taxes

The Third Circuit Court of Appeals sitting in Pennsylvania recently issued a precedential decision that interpreted the definition of a “named insured” under a tax delinquency statute to encompass tenants of a property even...more

The Walking Dead - Using Private Placement Variable Deferred Annuity Contracts to Enhance the Investment Return in Life Settlement...

by Gerald Nowotny on

Overview - I have always been a film fan. Growing up in the Panama Canal Zone, one of my Mother’s jobs for the Panama Canal Company was serving as the manager of the Balboa Theater. We used to watch initial screenings of...more

Florida Department Of Revenue Issues Advisement Determining That A Reinsurer And Its Cedents Did Not Have Nexus In Florida For Tax...

by Carlton Fields on

On January 13, 2017, the Florida Department of Revenue issued a Technical Assistance Advisement regarding whether a reinsurer had nexus with the state of Florida that would require it to file a corporate income tax return and...more

Split Dollar Shing-a-Ling! Employing the Concepts of Inter-Generational Split Dollar in Compensatory Split Dollar Arrangements

by Gerald Nowotny on

Overview - In the last ten years, life insurance producers and their counsel have quietly transferred great fortunes with minimal gift and estate taxation using intergenerational split dollar life insurance programs....more

Estate Tax Impact of Life Insurance Required by Divorce

by Charles (Chuck) Rubin on

Please see chart below for more information....more

IRS Treats Captives With Section 831(B) Elections As “Transactions Of Interest”

by Carlton Fields on

On the heels of Congress’ amendments last year to Section 831(b) of the Internal Revenue Code to curb perceived abusive use of so-called “micro” captive insurance companies, the IRS recently issued Notice 2016-66 officially...more

[Webinar] Business Planning in Light of Proposed Regulations under Code § 2704 - October 27th, 12:00p.m. CT

by Thompson Coburn LLP on

In this webinar, Steve Gorin, the author of his quarterly newsletter, will discuss the proposed regulations under IRC § 2704 that would increase the valuation of business entities in many cases. Attendees will learn when the...more

Tennessee Department Of Commerce And Insurance Issues Bulletin Advising Of Taxation Of Surplus Lines Premiums Post-NIMA...

by Carlton Fields on

In a special focus article in May, we wrote about the future of multi-state allocation of nonadmitted premium tax revenue following the dissolution of the Non-Admitted Insurance Multistate Agreement (NIMA). We followed up on...more

Upcoming CLE examines ways to avoid tax traps in life insurance

by Thompson Coburn LLP on

Beware that an employer-owned life insurance contract might not qualify for the usual exclusion from regular income tax. An “employer-owned life insurance contract” (a term that applied to much more than one would think) does...more

Put Me in Coach! Using Split Dollar Life Insurance Plans to Compensate Division I Coaches

by Gerald Nowotny on

In August 2016, the national sports media provided details regarding the compensation package for Coach Jim Harbaugh at the University of Michigan. It comes as no surprise to anyone that Division I football and basketball...more

Privacy Tip #51 – Check Up on Your Tax Preparer’s Data Security Measures

We have written before about the ability of hackers to file false tax returns to get fraudulent refunds by using the IRS website, and how hundreds of thousands of Americans have become victims of tax fraud. The IRS...more

2016 Captive Insurance Update | Issue 2 | 2016

by Downs Rachlin Martin PLLC on

Governor Peter Shumlin (D-Vt.) is not running for re-election this fall, so Vermont will have a new governor in January 2017. In addition, the Commissioner of the Vermont Department of Financial Regulation (DFR), Susan...more

Surplus Lines Clearinghouse Provides Instructions Following The Dissolution Of The Non-Admitted Insurance Multistate Agreement...

by Carlton Fields on

In a Special Focus article posted on May 2, 2016, we addressed the uncertain future of the multi-state allocation of non-admitted premium tax revenue. The Non-admitted and Reinsurance Reform Act (NRRA) provides for individual...more

New York Issues Two Advisory Opinions Regarding Surplus Lines Insurance

The New York State Department of Taxation and Finance (Department) issued two advisory opinions determining that unauthorized non-life insurance corporations (here, surplus lines insurance companies) are subject to insurance...more

Just How Is Basis Acquired After All?

by Bryan Cave on

Dorrance v. U.S., 2015 WL 8241954 (9th Cir. 2015) - This case is the latest in the cases involving tax impact of the sale of stock received by a policy holder from a mutual life insurance company on demutualization, and...more

New York State Denies Taxpayer's Insurance (Deduction) Claim - Tax Update Volume 2016, Issue 1

by Pepper Hamilton LLP on

Captive insurance arrangements, in New York and in certain other states, are often dependent on the federal treatment of the relationship as insurance for federal income tax purposes. A recent New York state...more

Health and Human Services, Labor and Treasury Departments Release New Summary of Benefits and Coverage Templates and Accompanying...

The Departments of Health and Human Services (“HHS”), Labor (“DOL”), and Treasury (the “Departments”) have jointly released final changes to the Summary of Benefits and Coverage (“SBC”) template, the Uniform Glossary, and...more

IRS Offers Tax Guidance Relating to Money Market Fund Rules

by Morgan Lewis on

The IRS recently provided relief from the RIC distribution requirement for money market funds that receive contributions in connection with the transition to a floating NAV, enabling RICs to top up their NAVs without having...more

Outsourced claims handling services attract VAT

by DLA Piper on

The CJEU has confirmed in the Polish referred case of Minister Finansów v Aspiro SA1 that a third party acting on behalf of an insurer in the handling and settlement of claims cannot benefit from the exemption for insurance...more

IRS Notice Offers Relief to Issuers of Variable Insurance Products in Response to Pending Money Market Fund Reforms

On May 5, 2016, the IRS issued Notice 2016-32, 2016-21 I.R.B. 1, which affords relief with respect to the application of the diversification requirements of IRC § 817(h) to variable life insurance and annuity contracts...more

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