Is Captive Insurance Right for Your Business? A Deep Dive with AkinovA
PODCAST: Benefits Companion - Captive Insurance Arrangements
Captive Insurance Arrangements
The Tax Court has invited amicus briefs and will address the codified meaning of the economic substance doctrine after increased IRS use of the doctrine to challenge taxpayer transactions. In a July 19, 2024, order in...more
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
Developments in Vermont 2023 - Captive Legislation - On May 8, 2023, Governor Phil Scott signed Vermont’s annual captive “housekeeping” bill into law. The 2023 legislation includes the following notable provisions...more
In an opinion published late last month, the United States Court of Appeals for the Third Circuit (“Third Circuit”) affirmed the Internal Revenue Service’s (“IRS”) authority to compel the production of documents and testimony...more
According to the IRS, the Dirty Dozen represents the worst of the worst tax scams. The Dirty Dozen is a list that is compiled annually by the IRS in order to alert taxpayers, tax professionals and financial institutions of...more
Developments In Vermont - Changes at the Top After more than five years of continuity, Vermont’s leadership team has seen significant turnover during 2022. In April, Michael Pieciak, the Commissioner of the Department...more
The Internal Revenue Service has announced the first installment of its annual “Dirty Dozen” list of tax scams. Published every year, the “Dirty Dozen” comprises the twelve most prevalent tax scams that taxpayers may...more
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
The measures taken by the Vermont Department of Financial Regulation (the “DFR”) in 2020 in response to the COVID-19 pandemic have been extended through 2021. These include a recognition that in-person board meetings in...more
Insurance: What is it? How does it work? Assume that Acme Co is paying premiums for commercial insurance coverage to protect itself from economic losses that may arise out of various events. These premiums are deductible...more
On December 1, 2020, the United States Supreme Court heard oral arguments in CIC Servs. LLC v. Internal Revenue Service, a case challenging the Internal Revenue Service’s (IRS) reporting requirements around certain...more
On January 31, 2020, the IRS issued a news release that warns taxpayers that it has created 12 new examination teams to audit abusive micro-captive insurance transactions. “Micro-captive” refers to a small insurance...more
Brydon DeWitt discusses captive insurance arrangement strategies with CPA Scott Bailey, Jr., a partner at Carr, Riggs & Ingram....more
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...more
Captive insurance companies are an elusive risk management strategy that, for many, is so poorly understood it is difficult to even begin consideration. Those who happen to fall into discussions of captives often bounce...more
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
Vermont's Leadership Team - Vermont’s leadership team largely stayed the course in 2017. Governor Phil Scott and Michael Pieciak, the Commissioner of the Department of Financial Regulation (the “DFR”), each completed a...more
In this case, Reserve Mechanical Corp. (“Reserve”), a captive insurer incorporated under the laws of Anguilla, sued the Commissioner of Internal Revenue in the U.S. Tax Court regarding the Commissioner’s findings of $477,261...more
In January 2017, the IRS Large Business and International Division initially announced the launch of a “compliance campaign process” in which IRS identifies compliance issues that present risk and require a response in the...more
On April 11, 2018, the General Assembly’s Revenue Laws Study Committee released a draft tax bill for possible introduction in the legislative session that convenes May 16. This Alert provides a summary of the more important...more
The Internal Revenue Service has warned taxpayers to be wary of abusive tax shelters, which remain on the annual “Dirty Dozen” list of tax scams for 2018. These sophisticated schemes, particularly those involving...more
The terms "captive insurance" and "federal income tax code" are anything but captivating. Yet, captive insurance has captivated the attention of the Internal Revenue Service ("IRS"), which has placed captive insurance on its...more
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
• 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
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