News & Analysis as of

Reinsurance Internal Revenue Code (IRC)

Eversheds Sutherland (US) LLP

Unlocking the process: Guide to ERISA individual prohibited transaction exemptions

Since 1996, the US Department of Labor granted more than 1,200 individual exemptions from the ERISA prohibited transaction rules. One of the distinctive features of ERISA is its prohibition, in ERISA section 406 as a...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

Locke Lord LLP

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

Locke Lord LLP on

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

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

Eversheds Sutherland (US) LLP

Congress Amends Section 831(b): Is This the Beginning of the End of Section 831(b) Abuses?

On December 18, 2015, Congress passed and President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 (Act), which made several significant amendments to section 831(b) of the Internal Revenue Code....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...

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

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