Tax Insurance

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News & Analysis as of

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

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

Now More Than Ever! The Planning Role of PPLI following Post-Trump Tax Reform

Overview - Donald Trump’s presidential inauguration is barely a week and a half away. It seems difficult to imagine that with a Republican-controlled House and Senate that President Trump he doesn’t get virtually...more

What Does a Trump Presidency Mean for the Affordable Care Act?

President-elect Trump has stated repeatedly that one of his initial goals is to repeal and replace the Affordable Care Act (the "ACA"). Because the Republicans control both houses of Congress, it seems likely that a repeal...more

Cures Act Lets Small Employers Reiumburse Premiums

On December 13, 2016, President Obama signed into law the 21st Century Cures Act, which allows small employers to maintain health reimbursement arrangements (HRAs) for the purpose of reimbursing employees for the cost of...more

Estate Tax Impact of Life Insurance Required by Divorce

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

Lawsuit filed to set aside IRS Notice 2016-66

Two months ago, without any prior warning or public notice, the IRS issued Notice 2016-66 which defined a number of common captive insurance transactions as “transactions of interest.” The Notice is limited to captive...more

Small Employers Have New Health Reimbursement Option Under Cures Act

The 21st Century Cures Act (Cures) signed by President Barack Obama on Dec. 13, 2016, contains a smorgasbord of health-related provisions, from reforming federal mental health policies to increasing funding for medical...more

Part 3: Exploring “Repeal and Replace”

In Part II of our blog series, Very Opaque to Slightly Transparent: Shedding Light on the Future of Healthcare, we considered potential healthcare market consequences of a partial repeal of the Affordable Care Act (ACA). In...more

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

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

ACA Tax Reporting Extensions

The IRS has once again extended the deadline for furnishing to employees the applicable tax forms required by the Affordable Care Act (ACA), and will continue to provide employers with penalty relief if they make good-faith...more

Captive Insurance - Looming IRS Reporting Deadline

Many businesses have been caught off guard by a recent Internal Revenue Service (IRS) notice that implicates a popular and commonly-used structure to manage risk. The notice employs a broad net and a short deadline, and...more

Employers Need To Be Aware Of Potential Pitfalls Of Providing Opt-Out Incentives To Company Health Insurance

In recent proposed regulations, the Internal Revenue Service (IRS) addressed how the Affordable Care Act (ACA) impacts the use of employer opt-out incentives, which are payments to employees who decline an employer’s group...more

Navigating the ACA in the Trump Era

On November 8, 2016, the future of the Patient Protection and Affordable Care Act (ACA) became more uncertain. Republicans in Congress have been working to repeal the ACA since it was passed in 2010, and now, with control of...more

UK Autumn Statement 2016: finance

In the 2016 Autumn Statement, the UK government confirmed, as previously announced, that from April 2017, it is to cap the amount of tax deductions for interest to the higher of 30% of taxable earnings in the UK or the net...more

Replacing The Affordable Care Act: A Reality Infusion

During the course of his campaign, President-elect Donald Trump repeatedly promised to repeal and replace President Obama's signature legislation, the Affordable Care Act (ACA). Certainly the Republican Party's continuing...more

Captive Insurance Arrangements Taking Advantage of Section 831(b) Election May Be Required to Report to the IRS

The Internal Revenue Service on November 1, 2016 issued Notice 2016-66 (the Notice) requiring information reporting with respect to certain insurance or reinsurance transactions (often referred to as micro-captive...more

McNees Insights Newsletter – Estate Planning: November 2016

IRS Simplifies Rules for Correcting Late Rollovers - On August 24, 2016, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2016-47, which greatly simplifies the procedure for correcting late rollover...more

Issue 102: ACA Post-Election Outlook

This is the one hundred and second issue in our series of alerts for employers on selected topics on health care reform. This series of Health Care Reform Management Alerts is designed to provide an in-depth analysis of...more

Urgent Captive Insurance Alert: IRS Lists 831(b) Micro-Captives as “Transaction of Interest”

On November 1, 2016, via Notice 2016-66 (2017-47 IRB) (link to notice), the Treasury Department and IRS declared certain captive insurance transactions under Code section 831(b) as “transactions of interest.” Commonly...more

IRS Provides Guidance on Reasonable Mortality Charges for Life Insurance Contracts Based on 2017 CSO Tables

On October 19, the Internal Revenue Service (IRS) issued an advance version of Notice 2016-63, addressing the “reasonable mortality charge” requirement under IRC §§ 7702 and 7702A for life insurance contracts based on the...more

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

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...

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

Bill Proposes Tax Incentives For Data Breach Insurance

On September 14, 2016, U.S. Representative Ed Perlmutter (D-Colo.) introduced the “Data Breach Insurance Act,” which would incentivize private industry to enhance its cybersecurity posture by providing federal income tax...more

Upcoming CLE examines ways to avoid tax traps in life insurance

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

[Webinar] Life Insurance to Fund Buyouts or Loss of a Key Person: Practical Ways to Avoid Tax Traps and Other Pitfalls - September...

Life insurance can help a business that loses an owner or other key person. Although life insurance death benefits can be tax-free, part or all of the benefits are taxable if not done the right way. Please join Steven B....more

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