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Tax Insurance

Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.

New Partnership Audit Rules – Plan Ahead Before the Tax Bill Arrives

by Carlton Fields on

A new set of rules for partnership audits (New Audit Rules), which generally take effect January 2018, fundamentally alter the manner in which the Internal Revenue Service (IRS) will conduct audits of partnerships,...more

News from Second & State

Weekly Wrap - With a national holiday on Monday and no session for either chamber, it was a quiet week in the Capitol. There was no movement on any legislation and very little budget talk. However, there is some news you...more

Takeaways from the Tax Court's First Micro-Captive Insurance Ruling

by Holland & Knight LLP on

• The U.S. Tax Court recently ruled in Avrahami v. Commissioner, the first litigated Tax Court case involving an 831(b) captive insurance company. • The Tax Court held that two of the key factors that define "insurance"...more

Health Care Reform Returns to the Spotlight

by Foley & Lardner LLP on

Congress is now back in session and, once again, focus has turned to health care. With all eyes on returning health care reform to the forefront, a flurry of activity has sparked new legislative efforts including the...more

IRS Challenges Ahead For Insurance Producers?

by Tonkon Torp LLP on

A 2017 Tax Court decision, Fleischer v. Commissioner, may call into question a tax planning strategy commonly used by commissioned brokers and salespersons in many industries. This Alert looks at the impact of the decision on...more

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

Health Care Reform Roundup – Issue 9

After health care reform efforts failed in late-Spring/early-Summer, things have been quiet. However, Congress returned to DC this week. Although legislative focus now appears to be on general tax reform, we expect some...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

Tax Court Issues Opinion Striking Down Captive Insurance Arrangement

by Fox Rothschild LLP on

The Tax Court has issued its long-awaited decision addressing captive insurance arrangements. In Avrahami v. Commissioner, 149 T.C. No. 7 (2017), the Tax Court held that payments made from a number of businesses owned by the...more

Tax Court Decides First Micro Captive Case

On August 21, 2017, the Tax Court issued its opinion in two companion cases Benyamin Avrahami and Orna Avrahami v. Commissioner, and Feedback Insurance Company, Ltd. v. Commissioner, 149 T.C. No. 7, holding against the...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

Health Care Reform Weekly Roundup – Issue 8

Below is a summary of significant health care reform developments over the past two weeks. GOP Repeal and Replace Efforts Stalled. After releasing a revised version of the Better Care Reconciliation Act (BCRA) on July 13,...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

Holland & Knight's Inaugural Israel Practice Newsletter - July 2017

by Holland & Knight LLP on

...We invite you to read our inaugural Israel Practice newsletter, in which our authors discuss pertinent American-Israeli topics. As Israel has been a crossroads and a prolific source of new ideas for more than 3,000 years,...more

Updated Health Care Reform Legislation Comparison Chart

The chart below compares key provisions of the Affordable Care Act (ACA), the American Health Care Act (AHCA) and the Better Care Reconciliation Act (BCRA). This chart is current as of July 13, 2017, and as of that date,...more

Here We Go Again - The Senate’s Health Reform Bill

by Winstead PC on

Late last week the Senate released its version of a health reform bill (the “Better Care Reconciliation Act of 2017” or the “Senate bill”) to fix the Patient Protection and Affordable Care Act (the “PPACA”). The Senate Bill...more

Highlights of Better Care Reconciliation Act

by Holland & Knight LLP on

U.S. Senate Republicans on June 22, 2017, unveiled a "discussion draft" of their healthcare plan, the Better Care Reconciliation Act. This memorandum provides highlights of key provisions. The Congressional Budget Office...more

The Better Care Reconciliation Act of 2017 vs. The American Health Care Act: Summary of Key Differences

On June 22, 2017, Senate Republicans released a discussion draft of their proposal to repeal and replace the Affordable Care Act (ACA), titled the “Better Care Reconciliation Act of 2017” (BCRA). Beyond the title change,...more

The Rise of the Group Health Insurance Captive

With its “employer mandate”—i.e., the requirement that applicable large employers make an offer of group health coverage to substantially all full-time employees or face the prospect of a penalty—the Affordable Care Act (ACA)...more

Health Care Reform Weekly Roundup – Issue 4

After a brief recess, Congress is back in session and health care reform negotiations continue. Below is a summary of a few, relatively minor, developments that took place during recess and the week of June 5th....more

Even Surplus Lines Laws Are Bigger and Better in Texas

by Zelle LLP on

On May 30, 2017, Texas House Bill 2492 made its final ascent to the office of Governor Greg Abbott. The bill passed through the Texas Legislature virtually unopposed. Assuming Governor Abbot signs the legislation, surplus...more

Issues for Employers as Health Care Legislation Moves to the Senate

by Jones Day on

ABSTRACT - Although the American Health Care Act, as passed by the U.S. House of Representatives, mainly affects the individual and small group health insurance markets, it has implications for large employers. The repeal of...more

CBO Releases Updated Cost Estimate of American Health Care Act of 2017

On May 24, 2017, the Congressional Budget Office (“CBO”) and the staff of the Joint Committee on Taxation (“JCT”) released a cost estimate for H.R. 1628, known as the American Health Care Act of 2017 (the “AHCA”). The CBO and...more

2017 Vermont Legislative Session | The Year in Review - DRM's Government & Public Affairs Team Final Analysis

by Downs Rachlin Martin PLLC on

A May 18th adjournment brought to a close the first half of the 74th biennial session of the Vermont General Assembly. Drama awaits as Gov. Phil Scott has threatened to veto H.518, the fiscal year 2018 budget, over an...more

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