Tax Finance & Banking Insurance

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News & Analysis as of

Required Summer Reading: Guidance Issued on the Tax Treatment of Guaranteed Minimum Benefit Hedges and Identified Mixed Straddles

The Treasury and the IRS offered two pieces of highly anticipated guidance on July 18 that are particularly relevant to the life insurance industry. ...more

Rules Will Allow Issuance of Longevity Insurance in Retirement Plans

On July 1, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final rules excluding qualifying longevity annuity contracts (QLACs) from the required minimum distribution rules (RMD...more

Real Property, Financial Services & Title Insurance Case Law Update

Neutral Evaluation/Sinkhole Litigation: trial court erred in sustaining objection to insurer’s notice of stay to invoke neutral evaluation process in lawsuit for breach of contract and damages for sinkhole losses to property...more

New Rule Allows Disability Insurance Premiums To Be Paid From Qualified Plan Accounts - Employers Will Be Able To Offer Employees...

HIGHLIGHTS - - The Treasury Department and the IRS released final regulations regarding amounts used by a qualified plan to pay for accident or health insurance premiums. Under the regulations, there is one notable...more

New York Budget Legislation

On March 31, 2014, New York State Governor Andrew Cuomo signed into law the 2014-2015 New York State Budget (Budget), which results in the most significant overhaul of New York’s franchise tax in decades. The Budget brings...more

Held Captive! The Closely Held Insurance Company - An Integrated Tax and Risk Management Solution

Overview - Captive or closely held insurance companies have been around a long time, at least fifty or more years. For most of their existence, captive insurance companies lived in relative anonymity and were mostly in...more

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

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

IRS Signals a Potential End to Its Administrative Pursuit of the Separate Account DRD

On February 4, the IRS issued a new revenue ruling – Rev. Rul. 2014-7 – that indicates that the IRS no longer plans to issue formal guidance concerning the treatment of the dividends-received deduction (DRD) with respect to...more

Insurance Topics We Will Be Watching in 2014

With the first month of the year behind us, this report outlines major insurance topics that we will be watching throughout 2014. Forces, trends and events that we believe will affect regulation, transactions and...more

FIO Focus, Issue No. 45: The Modernization Report: Federal Action May be Warranted

Devoted to exploring the progress of the modernization of the insurance industry, FIO Focus provides information and insights about the organizations and issues that are driving change and influencing the future of the...more

Wealth Management Update - January 2014

January Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The January § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more

Plan sponsors should take stock of all plan amendments

I didn’t have such a wonderful time at law school because I felt the administration and much of the faculty weren’t honest when it came to the study of law and more importantly, our job opportunities. There was one law...more

U.K. Autumn Statement 2013

The Chancellor of the Exchequer today delivered a 130-page Autumn Statement that contained a number of surprises, as well as expected updates on areas such as partnership taxation....more

Employee Benefits Update: 2013 Year End Plan Tasks

As we approach the end of the year, employers and plan sponsors of qualified retirement plans and health and welfare plans should take time to meet various upcoming deadlines. Failure to comply with the deadlines may result...more

Insurers Seek Enforcement Of State Law Protections For City Of Detroit GO Bonds

On November 8, 2013, three monoline insurers of the City’s general obligation bonds commenced adversary proceedings in the City of Detroit bankruptcy case. Through these actions, the monoline insurers seek to compel...more

Monthly Benefits Update - October 2013

Health & Welfare Plans - Health Care Reform: Federal Health Insurance Marketplace Opens With Technical “Glitches” - The federal health insurance marketplace (also known as the federal “exchange”) began accepting...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

Paul & Patty’s Potluck: Budget Conference Could Have Big Implications for Tax Reform

After weeks of tense negotiations, Congress passed legislation on October 16, 2013 to end the government shutdown and raise the debt ceiling. As part of the deal, congressional leaders agreed to establish a conference to...more

As shutdown week 2 approaches, 4 subtle signs of a possible deal

Congressional sources indicate, however, that a deal might not come together politically until very close to the October 17 - 18 deadline at which Treasury Secretary Jack Lew has warned Congress that, absent additional...more

Wealth Management Update - October 2013

The October § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 2.4%. This is up from September's 2.0% rate. The applicable federal rate ("AFR") for use with a sale to a defective...more

Pennsylvania Insurance Department’s Proposed Insurance Holding Company Regulations – Significant Changes Ahead

Pennsylvania insurers should be aware that proposed changes to Pennsylvania’s Insurance Holding Company regulations impose significant new requirements – especially for management agreements, service contracts, tax allocation...more

Real Property, Financial Services & Title Insurance Case Law Update: Week Ending September 20, 2013

I. FLORIDA STATE CASES - ILAN NIEUCHOWICZ & SASHA FUNK GRANAI - Ad Valorem Taxes: presumption that assessment correct lost in ad valorem tax challenge where taxpayer proves by preponderance of evidence either (i)...more

Legal Alert: An Ode to the Actuaries: Tax Court Concludes that Acuity’s Loss Reserves Were “Fair and Reasonable”

On September 4, the United States Tax Court issued its opinion in Acuity v. Commissioner, T.C. Memo. 2013-209. In brief, the court concluded that Acuity’s reserves for unpaid losses and loss adjustment expenses for 2006, as...more

September and October Filing and Notice Deadlines for Qualified Retirement and Health and Welfare Plans

Employers and plan sponsors must comply with numerous filing and notice deadlines for their retirement and health and welfare plans. Failure to comply with these deadlines can result in costly penalties and excise taxes. To...more

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