International Trade Tax Insurance

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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

Court Holds Excise Tax Does Not Apply to Foreign Retrocessional Reinsurance

In Validus Reinsurance, Ltd. v. United States, No. 13-0109 (ABJ), 2014 WL 462886 (D.D.C. 2014), the U.S. District Court for the District of Columbia found that although foreign reinsurance contracts covering certain U.S....more

No U.S. Excise Taxes On Foreign Retrocessions

Foreign retrocession insurance transactions are beyond the reach of IRS excise taxes based on the plain language of 26 U.S.C. § 4371(3), which aims to tax insurance transactions involving policies issued by foreign insurers...more

Legal Alert: IRS Issues Draft FATCA FFI Agreement and Announces Positive New Rules for Insurance Companies

On October 29, the Internal Revenue Service (IRS) issued Notice 2013-69, which includes guidance to foreign financial institutions (FFIs) entering into FFI agreements with the IRS and a draft FFI agreement. The Notice also...more

Reinsurance Newsletter - September 2013: Foreign Account Tax Compliance Act And Reinsurance

On July 12, 2013, insurance companies, banks and other financial institutions, received a reprieve from the Internal Revenue Service (“IRS”). The agency delayed, by six months, withholding and other requirements mandated by...more

U.S. Employee Benefit Plans Must Comply with Supreme Court’s DOMA Decision: What to Do Now and What Is Still Undecided

When the United States Supreme Court struck down the Defense of Marriage Act (DOMA) provision defining marriage under federal law as between a man and a woman, the decision had broad implications for U.S. employee benefit...more

A Whiter Shade of Pale -- Building a Private Label Investment Program with Private Placement Life Insurance and Annuities

Overview - Poor John Paulsen! Now that's an oxymoron! He has to be the most radioactive man on the Planet when it comes to tax planning. Everything he touches in business seems to be couched in subversive tax planning...more

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

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

Il Regime Fiscale Delle Polizze Assicurative Estere Offerte In Regime Di Libera Prestazione Di Servizi

La recente Circolare dell’Agenzia delle Entrate n. 41/E del 31 ottobre 2012 è intervenuta a chiarire le modifiche alle disposizioni fiscali in materia di imposte sostitutive sui redditi di capitale di natura assicurativa e di...more

An American in Paris (or Shanghai or Tel Aviv) – Part 3: How to retain your account in a Foreign Financial Institution

In my last installment, I discussed the benefits of a private placement insurance contract (life insurance or annuity) issued by a life insurer domiciled in Puerto Rico – Isla del Encanto – for Americans living...more

An American in Paris (or Shanghai or Tel Aviv) – Part 2: Using Tax-Advantaged Investment to Minimize U.S. Tax Reporting...

If you are an American living overseas, the walls are closing in on you quickly. If your foreign bank hasn’t already closed your account, don’t hold your breath because it is probably coming quickly. A large number of...more

An American in Paris (or Shanghai or Tel Aviv) – Part 1: Using Tax-Advantaged Investment Solutions While Living Overseas

According to the American Citizens Abroad, there are five-seven million American citizens living outside of the United States on a fulltime basis. I for one am green with envy. I grew up in the Panama Canal Zone and know...more

Life insurance and Annuity Planning for Non-Resident Aliens from a U.S. Tax Perspective

Many non resident aliens (NRAs) own U.S. life insurance, i.e. life insurance issued by a life insurer domiciled in the United States. Why is this case? A range of planning reasons explains how this came to be....more

A Message to UBS! (and Other Swiss Private Banks)

A. Overview - Over the course of the last twelve years that I have been active in the recommendation of private placement insurance solutions, I have had the opportunity to meet and solicit business with a number of...more

Strategic Investment Tax Planning for Non-Resident Aliens Using Private Placement Variable Annuities – Part II

Part I of this article addressed the potential benefits of private placement variable annuities (PPVA) for wealthy non-resident alien taxpayers. Generally, tax treaties make all of this possible. As a result, annuities are...more

ObamaCare’s Impact on Expatriate Investment Fund Partners

The United States Supreme Court upheld the constitutionality of the Health Care and Education Reconciliation Act of 2010 (commonly referred to as ObamaCare) in a decision released June 28, 2012. A copy of the decision...more

FATCA G-5 Model Intergovernmental Information Sharing Agreements Released, with Substantial Benefits for Insurance Company FFIs...

On July 26, 2012, the Treasury Department released two versions of a model intergovernmental agreement (model IGA) for government-to-government information sharing under the Foreign Account Tax Compliance Act (FATCA). One...more

Global HR Hot Topics: Expatriates, US Tax Withholding, US Social Security Contributions—And COBRA

Employer income tax withholding, social security contributions and employee benefits mandates usually amount to a straightforward issue of the local law at the place of employment. An employee working in Italy is subject to...more

Considering Operations Overseas? - What Every Nonprofit Should Know Before Crossing US Borders

Preliminary Considerations for Trade Activities Abroad Organizational Options - Specific/ Isolated Event v. Ongoing Presence ..Use of Association Management Company ..Host a...more

Representing a Client Investing Abroad

Doing business abroad, in any country, poses unique issues and challenges. Nevertheless, there are common issues inherent in each deal and each location. In an offshore transaction, it is essential to evaluate and minimize...more

New International Tax Provisions Take Aim at Foreign Tax Credit Planning But Also Provide Some Relief Under Section 6501(c)(8)

On August 10, 2010, President Obama signed into law the Education Jobs and Medicaid Assistance Act, P.L. 111-226, which provides funds to the states for teachers’ salaries and Medicaid costs. To fund this bill, Congress...more

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