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Tax Deductions Insurance Industry

Carlton Fields

Tax Court Upholds IRS Decision That Premiums Paid to Microcaptive Insurance Companies Did Not Qualify for Tax Deductions

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The U.S. Tax Court recently upheld a determination by the IRS that premium payments to certain microcaptives could not be deducted for tax purposes because the premium payments were not actually for “insurance.”...more

Chambliss, Bahner & Stophel, P.C.

IRS Issues Long-Term Care Premium Deductibility Limits for 2019

The Internal Revenue Service (IRS) is increasing the amount taxpayers can deduct from their 2019 income as a result of buying long-term care insurance. Premiums for "qualified" long-term care insurance policies (see...more

Carlton Fields

Tax Reform: Insurance Company Provisions

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Recent tax legislation, informally known as the Tax Cuts and Jobs Act (the “Act”) contains several changes that affect the insurance industry....more

Carlton Fields

New Tax Law Eliminates 30-Day Safe Harbor Against CFC Status

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The recent tax law changes have focused primarily on corporate income tax, and in the international context, mostly on outbound tax matters. However, certain less publicized changes to the Code’s controlled foreign...more

Locke Lord LLP

New Tax Law May Reduce Tax Benefit for Cross-Border Affiliated Insurance/Reinsurance Premiums

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On December 22, 2017, the President signed into law H.R. 1, known generally as the Tax Cuts and Jobs Act (the “TCJA”), which makes widespread changes to the Internal Revenue Code. The TCJA includes a number of provisions that...more

Cadwalader, Wickersham & Taft LLP

Fifteen Key Provisions in the Final Tax Reform Bill

On December 20, 2017, the Senate and House of Representatives passed H.R. 1, known as the “Tax Cuts and Jobs Act” (“Tax Reform Bill”). President Trump is expected to sign the Tax Reform Bill by early January. The Tax Reform...more

Cadwalader, Wickersham & Taft LLP

Seventeen Provisions to Watch in the Senate Tax Reform Bill

On December 2, 2017, the Senate passed a tax reform bill that differs in some key aspects from the tax reform bill the House approved on November 16, 2017. A House and Senate conference committee will begin work to resolve...more

Eversheds Sutherland (US) LLP

Reconciling the Differences, the Senate Tax Cuts and Jobs Act

On November 9, 2017, the Senate Finance Committee released a Description of the Chairman’s Mark of the “Tax Cuts and Jobs Act” and on November 14, 2017, the Senate Finance Committee released a Description of the Chairman’s...more

Cadwalader, Wickersham & Taft LLP

Fifteen Provisions to Watch in the Tax Reform Proposals

On November 14, 2017, Senate Finance Committee Chairman, Orrin Hatch (R-Utah), released his modified tax reform plan (“Senate Bill”), which adopts some of the House Bill proposals (as amended) (“House Bill”), but also...more

Carlton Fields

Tax Court Disallows Deductions For Payments To Captive Insurance Company

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A husband and wife who paid $1.54 million in premiums to their captive insurance company and $720,000 in premiums to another insurer over two years, almost all of which ended up back in their bank accounts, have had their tax...more

Cadwalader, Wickersham & Taft LLP

Eleven Business Provisions to Watch in the House Tax Reform Bill

On November 2, 2017, Republicans in the House of Representatives released their long-anticipated tax reform bill (the “Bill”) which includes significant changes to the current U.S. federal income tax regime for businesses and...more

Holland & Knight LLP

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

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• 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

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 8, Issue 9

Appellate Division Reverses Tribunal and Remits Case for Consideration of Sales Tax Refunds - The New York State Appellate Division, in a strongly worded opinion, reversed the decision of the Tax Appeals Tribunal denying...more

Shumaker, Loop & Kendrick, LLP

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

Akerman LLP - Health Law Rx

House Republican Health Care Bill: Good News for Health Insurance Executives

An Affordable Care Act (ACA) provision that is often-overlooked by the media, but has impacted the ability of insurers and their non-insurance related entities, in their role as employers, to take tax deductions for certain...more

Troutman Pepper

New York State Denies Taxpayer's Insurance (Deduction) Claim - Tax Update Volume 2016, Issue 1

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Captive insurance arrangements, in New York and in certain other states, are often dependent on the federal treatment of the relationship as insurance for federal income tax purposes. A recent New York state...more

Carlton Fields

Stretched for Resources, the IRS Sets Its Sights on Small Captive Insurers

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A "captive" insurance company is an insurer formed for the limited purpose of insuring the risks of its non-insurer owner or owners. A captive can be an effective risk-management tool, especially for costly or unconventional...more

Eversheds Sutherland (US) LLP

Camp Goes All-In with Comprehensive Tax Plan: Highlights, Tax Reform Status and Impact on Taxpayers

On February 26, Representative Dave Camp (R-Mich.), chairman of the House Ways and Means Committee, released his much-awaited comprehensive tax reform plan (the “Camp Proposal”). That proposal seeks to cut marginal tax rates...more

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