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Internal Revenue Service Reinsurance

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Downs Rachlin Martin PLLC

Captive Insurance Update | Spring Edition | 2024

On March 27, 2024 the Vermont Captive Insurance Association (VCIA) held its biannual “Roadshow” educational event designed for prospective captive insurance companies. The Roadshow, which has been hosted in over 20 cities,...more

Eversheds Sutherland (US) LLP

Charting a course: Guidance issued to help navigate potential issues for insurance industry with the corporate alternative minimum...

On February 17, 2023, the Department of Treasury (Treasury) and the Internal Revenue Service (the IRS) issued Notice 2023-20 (the Notice), to provide guidance that is intended to help avoid unintended adverse consequences to...more

Downs Rachlin Martin PLLC

Captive Insurance Update | Fall Edition 2021

Developments in Vermont Federal Issues State Issues Continued Impact of COVID-19 - The measures taken by the Vermont Department of Financial Regulation (the “DFR”) in 2020 in response to the COVID-19 pandemic have been...more

Downs Rachlin Martin PLLC

Captive Insurance Update | Spring Edition | 2019: A summary of state and federal developments in the captive insurance industry

There were no significant changes in Vermont’s leadership team during the last election cycle. Governor Phil Scott, a Republican, was re-elected in November 2018 for another two-year term. Michael Pieciak, the Commissioner of...more

Manatt, Phelps & Phillips, LLP

Health Update - November 2016

Post-Election Analysis: Healthcare Antitrust in a Trump Administration - In a Republican sweep of all the elected branches of the federal government, Donald Trump won the presidential election and Republicans retained...more

McDermott Will & Emery

IRS Adjusted ACA Fee Amounts for the 2017 Policy or Plan Years

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The Patient-Centered Outcomes Research Institute (PCORI) fee was established under the Affordable Care Act (ACA) to advance comparative clinical effectiveness research. The PCORI fee is assessed on issuers of health insurance...more

Locke Lord LLP

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

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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

Downs Rachlin Martin PLLC

2016 Captive Insurance Update | Issue 2 | 2016

Governor Peter Shumlin (D-Vt.) is not running for re-election this fall, so Vermont will have a new governor in January 2017. In addition, the Commissioner of the Vermont Department of Financial Regulation (DFR), Susan...more

Carlton Fields

IRS Revokes Ruling That Imposed Excise Tax On Wholly Foreign Reinsurance Transactions

Carlton Fields on

The Internal Revenue Service recently revoked a 2008 ruling that a 1% excise tax under section 4371(3) of the Internal Revenue Code applied to “reinsurance premiums paid by one foreign insurer or reinsurer to another.” The...more

Locke Lord LLP

Insurance Newsletter September 2015

Locke Lord LLP on

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

Proskauer Rose LLP

Wealth Management Update - September 2015

Proskauer Rose LLP on

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

Locke Lord LLP

Validus Round Two: Court of Appeals’ Decision Holding That Wholly-Foreign Retrocessions Are Not Subject to Federal Excise Tax...

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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

BakerHostetler

The IRS Turns Up the Heat on Hedge Fund-Backed Reinsurance

BakerHostetler on

After years of inaction, the Internal Revenue Service (IRS) is throwing up obstacles to enjoying the tax advantages of hedge fund-backed reinsurance. On April 24, 2015, the IRS issued a notice of proposed rulemaking titled...more

Carlton Fields

D.C. Circuit Holds That Wholly Foreign Retrocessions Not Subject To U.S. Excise Tax

Carlton Fields on

In late May, the United States Court of Appeals for the District of Columbia Circuit affirmed a grant of summary judgment to a reinsurer in a dispute with the IRS regarding the imposition of U.S. excise taxes on a wholly...more

Eversheds Sutherland (US) LLP

Validus Affirmed for All the Right Reasons – The FET Does Not Apply to Wholly Foreign Reinsurance Transactions

On May 26, the U.S. Court of Appeals for the District of Columbia affirmed the result of the U.S. District Court for the District of Columbia in Validus Reinsurance, Ltd. v. U.S., 19 F. Supp. 3d 225 (2014), which was the...more

Carlton Fields

IRS Proposes Regulations Directed To “Passive” Hedge Fund Foreign Insurance Entities

Carlton Fields on

On April 24, 2015, the Internal Revenue Service proposed regulations directed to “situations in which a hedge fund establishes a purported foreign reinsurance company in order to defer and reduce the tax that otherwise would...more

McDermott Will & Emery

IRS Rules Captive Reinsurance Arrangement Involving Retiree Medical Benefits Qualifies as Insurance for Federal Tax Purposes

On May 18, 2014, the Internal Revenue Service (IRS) ruled that an employer’s wholly owned captive insurance subsidiary could reinsure the employer’s retiree medical benefit risks and still qualify as insurance for federal tax...more

Eversheds Sutherland (US) LLP

Whose Risk Is It Anyway? New Revenue Ruling Provides Guidance for Employee Benefits Captives

On May 8, the IRS issued Rev. Rul. 2014-15, 2014-22 I.R.B. 1, which provides guidance in the rapidly expanding area of insuring or reinsuring employee benefits with captives. ...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

New Health Care Reform Fees—Will You Be Required to Pay?

The Patient Protection and Affordable Care Act established two fees to be paid by insurers and self-insured plans: (1) the Transitional Reinsurance Program (TRP) fee to raise revenue for health insurance issuers that cover...more

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