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Long-awaited passive foreign investment company proposed regulations – focus on insurance

On July 11, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued comprehensive proposed regulations on passive foreign investment companies (PFICs) that include guidance on the...more

LB&I announces new campaigns – Related-party service companies, offshore private banking and loose-filed Forms 5471

On April 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced three new compliance campaigns. The campaigns focus on: ..Transfer pricing for “captive” services...more

BEAT, FATCA and Insurance - proposed regulations clarify the application of the BEAT and the treatment of insurance premiums under...

On December 13, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued two sets of proposed regulations of importance to insurance companies. One set was the long-awaited regulations...more

IRS provides IRC § 817(h) diversification guidance on a new form of mortgage-backed security to be issued by Fannie Mae and...

On October 16, 2018, the Internal Revenue Service (IRS) released Rev. Proc. 2018-54, which addresses the treatment of a new mortgage-backed security under the diversification rules of IRC § 817(h). This new security, called a...more

Tax Court Decides First Micro Captive Case

On August 21, 2017, the Tax Court issued its opinion in two companion cases Benyamin Avrahami and Orna Avrahami v. Commissioner, and Feedback Insurance Company, Ltd. v. Commissioner, 149 T.C. No. 7, holding against the...more

Treasury and the IRS Offer a New Take on the PFIC Active Insurance Exception

On April 23, Treasury and the IRS issued proposed regulations interpreting the active insurance exception under the passive foreign investment company (PFIC) rules. Although the release of the proposed regulations did not...more

FY 2016 Budget Tax Proposals Target Insurance Companies

On February 2, the Obama Administration released its fiscal year 2016 budget (FY 2016 Budget). The hallmarks of the FY 2016 Budget are proposals that would impose (i) a minimum tax on the current foreign earnings of U.S....more

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

After All the Preparation, It’s Finally Here: FATCA Becomes Effective July 1, 2014

More than four years after Congress enacted the Hiring Incentives to Restore Employment Act of 2010, Pub. L. 111-147, which added the Foreign Account Tax Compliance Act (FATCA) provisions to the Internal Revenue Code, FATCA...more

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

IRS Declares 2014 and 2015 as a Transition Period for FATCA Administration and Enforcement and Provides an Additional Six Months...

Pursuant to Notice 2014-33 (the Notice), the IRS announced that it will treat calendar years 2014 and 2015 as a transition period for the administration and enforcement of the due diligence, reporting, and withholding...more

5/9/2014  /  Due Diligence , Enforcement , Extensions , FATCA , FFI , IRS

FY 2015 Budget Tax Proposals Target Insurance Companies

On March 4, the Obama Administration released its fiscal year 2015 budget (FY 2015 Budget). In keeping with the Administration’s past budgets, the FY 2015 Budget includes a number of tax proposals that target insurance...more

Potential Impact of the Tax Reform Act of 2014 on Insurance Companies

On February 26, House Ways and Means Committee Chairman Dave Camp (R-Mich.) released a “Discussion Draft” of the Tax Reform Act of 2014, which sets forth his much-anticipated tax reform proposals. Of note, the Discussion...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

Victory for the Taxpayer in Validus: District Court Holds that Federal Excise Tax Does Not Apply to Retrocessions

On February 5, the U.S. District Court for the District of Columbia issued its opinion in Validus Reinsurance, Ltd. v. United States, which is the first case to involve a challenge to the IRS’s position on the “cascading”...more

Leaving a Legacy: Divided Tax Court Allows Deductions for Insurance Premiums Paid to Captive Insurance Affiliate

On January 14, the United States Tax Court issued a reviewed opinion in Rent-A-Center Inc. v. Commissioner, 142 T.C. 1 (2014), which held that subsidiaries of Rent-A-Center Inc. (RAC) were entitled to claim deductions for...more

1/20/2014

FIO Report Sets the Agenda for Discourse on the Future of Insurance Regulation

On December 12, 2013, the Federal Insurance Office (FIO) of the U.S. Department of the Treasury released its much anticipated study, How to Modernize and Improve the System of Insurance Regulation in the United States...more

Legal Alert: New York Adopts Holding Company Act Amendments

On July 31, 2013, Governor Cuomo signed into law New York Assembly Bill 7807A, which adopts key changes to the regulation of insurance holding company systems in New York under Article 15 of the New York Insurance Law and the...more

Legal Alert: FATCA NFFE Rules Subject Non-U.S. P&C Insurers and Reinsurers to Burdensome Reporting Requirements

The good news is that, under the recently released Foreign Account Tax Compliance Act (FATCA) regulations, most non-U.S. property and casualty (P&C) insurance and reinsurance companies will not be considered foreign financial...more

Proposed Legislation Would Sweep Certain Offshore Corporations into the U.S. Tax Net and Subject Their Worldwide Income to U.S....

The Stop Tax Haven Abuse Act and the International Tax Competitiveness Act of 2013 are two parts of a package of three bills introduced in the U.S. House of Representatives on April 15 by Rep. Lloyd Doggett. A significant...more

Legal Alert: New Budget Proposals Once Again Target Insurance Companies

On April 10, the Obama Administration released its fiscal year 2014 budget (FY 2014 Budget). Of note, the FY 2014 Budget includes a number of tax proposals that target insurance companies or that otherwise would have a direct...more

Legal Alert: IRS Proposes Rules on Health Insurer Fee

The Internal Revenue Service (IRS) has released proposed regulations on the health insurer fee under section 9010 of the Patient Protection and Affordable Care Act (PPACA). The regulations, which were published in the Federal...more

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