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Internal Revenue Code (IRC) Tax Liability Insurance Industry

Gerald Nowotny - Law Office of Gerald R....

Still the One! – The Use of Private Placement Life Insurance in Tax Planning for Trial Attorneys with Contingency Fee Income

In the Soundtrack of Our Lives, one of the songs that I still get to hear from time to time on Sirius XM, is “Still the One” which was recorded and released by the band Orleans in 1976. I was in the tenth grade just to be...more

Gerald Nowotny - Law Office of Gerald R....

Las Mañanitas

Recently (January 15th) I celebrated my sixty fifth birthday. Where did the time go? If my East German father Willy Wolfgang Nowotny were still with us, I could hear him say, “Too soon old, too late smart.” While I was never...more

Woodruff Sawyer

Tax Liability Insurance: Overview & 2024 Market Update

Woodruff Sawyer on

Nearly all carriers will list the above exclusions; however, some may also exclude Fraud and Settlement without Consent from coverage. As with RWI, Tax Liability Policies are non-renewable. They have a one-time premium...more

McDermott Will & Emery

Weekly IRS Roundup January 3 – January 6, 2023

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 3, 2023 – January 6, 2023...more

Carlton Fields

U.S. Tax Court Finds Captive Insurer Is Not an “Insurance Company” Under the Internal Revenue Code

Carlton Fields on

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

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