Tax Business Organization Insurance

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Bipartisan Budget Agreement Triggers New Audit Rules for Partnerships; Repeals ACA Automatic Enrollment

On November 2, 2015, President Obama signed into law the Bipartisan Budget Agreement of 2015, H.R. 1314, which, in addition to lifting mandatory spending caps and raising the federal debt ceiling, has repealed the Affordable...more

Tax Policy Update

NUMBER OF THE WEEK: 10 percent. Rate of the one-time deemed repatriation tax on U.S. multinationals’ foreign earnings under GOP presidential candidate Donald Trump’s tax plan released Sept. 28. The revenue raised through...more

Tax Court Holds that Residual Value Insurance Qualifies as Insurance for Tax Purposes

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

Special Focus: What The Insurance Industry Should Know About The IRS’s Campaign Against “Abusive” Micro Captives

Though in the midst of a stifling budget and personnel reduction, the United States Internal Revenue Service (“IRS”) recently announced an increased effort to curb what it sees as widespread abusive applications of so-called...more

Locke Lord QuickStudy: Validus Court of Appeals Decision - Wholly-Foreign Retrocessions Not Subject to Federal Excise Tax

On May 26, 2015, the United States Court of Appeals for the District of Columbia upheld a District Court decision and ruled that the Internal Revenue Service could not impose excise tax on certain wholly-foreign retrocessions...more

Locke Lord QuickStudy: Proposed Regulations Issued On Hedge Fund Reinsurance Transactions

The Internal Revenue Service (IRS) recently issued proposed regulations addressing what constitutes the “active conduct of an insurance business” for purposes of the passive foreign investment company (PFIC) rules (the...more

2015 Federal Budget – Selected Tax Measures

On April 21, 2015, the Minister of Finance presented Canada’s long-awaited 2015 Federal Budget (the 2015 Budget). The 2015 Budget includes a number of taxpayer-friendly measures, including limited relief from Canadian source...more

"MassMutual Victory May Pave the Way for Earlier Deductions"

Earlier this month, Massachusetts Mutual Life Insurance Company (MassMutual), represented by Skadden, won a federal appeal permitting the company to deduct policyholder dividends in the year the dividends were declared, even...more

Focus on Tax Controversy - Spring 2015

In This Issue: - Fifth Circuit Ruling in BMC Software, Inc. v. Comm’r. Is Good News for Taxpayers - When Is a Second Inspection Not a Second Inspection? - Captive Insurance Litigation: Key 2014 Cases ...more

California Tax Developments - A Reed Smith Quarterly Update (3rd Quarter 2014)

Case Updates - Court finds ownership of LLC membership interest does not constitute doing business in California On November 14, the Fresno County Superior Court determined that Swart, an Iowa-based corporation with a...more

Is a quiet (silent) trust illusory?

Is a quiet or silent trust illusory? The question is intentionally ambiguous. Is the question whether the trust itself is illusory, or just its quietness? A quiet or silent trust has been defined as “an irrevocable trust...more

Legal Alert: New York Tax Reform to Impact Captive Insurance Companies

In January, New York Governor Andrew Cuomo proposed broad corporate tax reform in his budget bill, which is currently winding its way through the legislature. The most significant proposal is a shift from a separate entity...more

Death of the Salaried Partner? Wide Ranging Changes to LLP Member Taxation To Come Into Force on 6 April 2014

Wide ranging changes to the way in which LLP members are taxed are due to take effect on 6 April 2014. LLPs and their members, particularly those in professional service and private equity/fund management firms, should,...more

Illinois Appellate Court Respects Characterization of Captive Insurance Company

In Wendy’s International, Inc. v. Brian Hamer, decided earlier this week, the Illinois Appellate Court found that Taxpayer had met its burden and proved that its subsidiary insurance company was a bona fide insurance company...more

The Power of Insurance Trusts to Maintain Family Business Assets and Sanity

Life insurance and irrevocable trusts are great tools to ease family business succession issues and mitigate exposure to shareholder oppression and disputes. Irrevocable life insurance trusts (ILIT), in particular, play an...more

Corporate & Securities Law Alert: September 2013 - Captive Insurance: A Niche for the Middle Market

With insurance premiums on the rise and the uncertain state of the federal tax system, middle market business owners may be looking for a source of stability that allocates the risks associated with operations. A “small”...more

It's Your Business News -- August 2013

In This Issue: Making the ‘Right’ Choice; Top Ten Mistakes Businesses Make Regarding Insurance; and You’ve Got the Job, Details Will Follow. Excerpt from Making the ‘Right’ Choice - You have the idea, you...more

Provisions of Affordable Care Act Could Impact Tax-Exempt Status of Certain Bonds

Certain payment models created under the Patient Protection and Affordable Care Act intended to coordinate care and lower healthcare costs raise questions concerning the tax-exempt status of debt issued by certain healthcare...more

Affiliates of Health Insurance Providers May Be Subject to the Affordable Care Act $500,000 Deduction Limit on Executive...

Most issuers of healthcare insurance likely have heard about the $500,000 limit on deductible compensation that became effective January 1, 2013, but might be surprised to know how much broader the scope of the deduction is...more

California Insurance-Related Bills Meet Deadline for Passage in 2013

The deadline for Assembly bills to be passed by the California State Assembly and for Senate bills to be passed by the California State Senate was last Friday, May 31. ...more

New Guidance for Tax-Exempt Hospitals on Community Health Needs Assessment and Other Section 501(r) Requirements

On April 5, the Treasury Department released proposed regulations that provide guidance on the community health needs assessment (“CHNA”) and other requirements for tax-exempt hospitals under section 501(r) of the Internal...more

As Clear as Mud! The Investment Diversification Rules for Private Placement Insurance Products

A. Overview - The investment diversification rules are a critical element in planning for private placement insurance products. One of the underlying marketing premises for the attractiveness of private placement...more

Union Friendly - Using Collectively Bargained Benefit Plans to Maximize Employee Benefit Plan Contributions for Closely Held...

Overview - Part I and Part II have focused on the tax planning possibilities of small business owners and owners of professional corporations utilizing an exemption for collectively bargained plans. This exemption allows...more

Panning for Gold in the Ivory Tower – Using Split Dollar and Private Placement Life Insurance to Compensate Senior Executives of...

Overview - Charitable organizations from hospitals to universities have a difficult time attracting and retaining top executive talent from the world of public corporations. Public corporations provide competitive...more

Perspectives - Fall 2012 | Volume 3, Edition 2: An Executive Compensation, Benefits & Human Resources Law Update

In This Edition: - Year-end Deadline for Correcting Section 409A Deferred Compensation Arrangements That Condition Payment on an Employee Release or Covenant: By December 31, 2012, all deferred compensation...more

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