IRS keeps pressure on 831(b) with ‘Dirty Dozen’ return

The Internal Revenue Service has published its annual Dirty Dozen list of...
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Exclusive: MIJS court victory against IRS a ‘game changer’ in 831(b) fight

A Summons issued by the Internal Revenue Service (IRS) to Moore Ingram...
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Captives of all sizes will benefit from Vermont tax credit change – David Provost

The proposed tax credit change in Vermont’s latest captive bill will, if...
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CIC Services drops IRS lawsuit after Notice 2016-66 extension

CIC Services, LLC has dropped the lawsuit it filed against the United...
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IRS extends Notice 2016-66 deadline by 90 days

Captive managers and material advisors working with captives making the 831(b) tax...
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Exclusive: OECD to meet risk management associations at RIMS 2017

The risk management community appears to have made a breakthrough in its efforts...
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FERMA meeting with OECD just the start – Carl Leeman

Carl Leeman, chairman of the Working Group on Captives for the Federation...
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Tax opinion analyses 831(b) acquisition options

Owners of captives making the 831(b) tax election and wanting to get...
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FiscalReps launches TAXBOX2

FiscalReps, specialists in tax advisory and consultancy, has unveiled its “end to...
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Colorado Senator first to lobby IRS over “burdensome” Notice 2016-66

A Democratic senator from Colorado has written to the Commissioner of the...
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Industry slams ‘deliberately bad timing’ of IRS’ latest 831(b) Notice

The Internal Revenue Service (IRS) intentionally waited until the busy season to...
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IRS gives captives three months to report, throws fuel on 831(b) fire

The United States Department of the Treasury and the Internal Revenue Service...
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SIIA and 15 captive associations lobby for Federal guidance on 831(b) rules

The Self-Insurance Institute of America (SIIA), along with 15 state captive insurance...
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Delaware outlines streamlined application process for 831(b) compliance

The Delaware Department of Insurance has issued a bulletin detailing two procedures...
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French tax authorities expected to take closer look at captives

Tax audits of large multinationals by the French tax authorities are expected...
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Exclusive: EY building working group to engage OECD on Beps

EY, the multinational professional services firm, is recruiting industry leaders and experts...
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Last ditch attempt to remove premium reporting from FATCA

The United States Congress will consider a new bill that seeks to...
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Avrahami ruling may be delayed until mid-2017

America’s captive insurance industry will have to keep waiting for further clarity...
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FERMA weighs in on Beps debate by publishing position paper

The Federation of European Risk Management Associations (FERMA) has made a vigorous...
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Industry must make captive case as Beps project marches on – Fabrice Frère

Fabrice Frère, managing director of Aon Risk Solutions in Luxembourg, has called...
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IRS losing Avrahami could create open season for 831(b)s – Gary Osborne

Gary Osborne, president of USA Risk Group, believes the Internal Revenue Service...
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Governor signs Tennessee captive legislation focusing on re-domestications

Amendments to Tennessee’s captive statute, including a one-year premium tax holiday for...
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EU public tax reporting will lift lid on European captives

The European Commission’s drive for greater tax transparency will bring the continent’s...
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Cayman Islands stands ground against public register of ownership

The Cayman Islands and the government of the United Kingdom agreed on...
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Non-traditional risks entering captives, more pressure on actuarial analysis – Chris Lay

Businesses are increasingly turning to captives to provide solutions for non-traditional risks,...
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US Tax Court sides with IRS in pending micro-captive case

The Internal Revenue Service (IRS) has won an early victory in its...
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Guernsey well prepared for BEPS scrutiny – Dominic Wheatley

The well-developed and skilled insurance industry in Guernsey means the jurisdiction is...
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Singapore to scrap tax exemptions for captives

The tax incentive scheme for captive insurers in Singapore will be subsumed...
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New York ruling challenges tax deductibility for captive premium

The premiums paid to a captive by a New York-based convenience store...
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UK chancellor increases IPT to 10%

The United Kingdom’s Chancellor of the Exchequer, George Osborne, has increased the...
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Investors circling to purchase unwanted 831(b) captives

A new market for the acquisition of 831(b) tax electing captives has...
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Self-procurement tax liability is misunderstood – Asher Harris

The spate of re-domestications to ‘home-state’ domiciles as a result of aggressive...
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Exclusive: Illinois begins talks to revamp captive statute

A captive insurance bill for the State of Illinois is currently being...
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Texas re-domestications gather momentum

Texas is increasingly using the “stick” approach to encourage firms headquartered in...
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Dirty Dozen Captives: Rule or Exception?

Ryan Work is vice president of government affairs for the Self-Insurance Institute...
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Micro captives keep their place on the IRS “Dirty Dozen” list

The United States’ Internal Revenue Service has placed captive insurance on its...
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Changes to 831(b) – What now?

The 831(b) tax election for small captives continues to fill column inches....
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EU cites offshore reinsurance arrangements in latest anti-BEPS measures

The European Union (EU) looks set to increase its scrutiny of multinationals’...
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The States’ Role in Regulating Small Captives

Small captives are rarely out of the headlines and under intense scrutiny...
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Industry schism is losing the IRS fight over small captives – Jay Adkisson

The lack of unity within the United States’ captive insurance industry has...
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Some smaller captives will have to restructure or close – regulators

A number of smaller captives making the 831(b) tax election will have...
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Small modifications made to 831(b) legislation, sent to House

The tax extender package including significant changes to the 831(b) tax election...
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831(b) uncertainty not impacting formation numbers

Captive managers and state regulators remain upbeat in the face of continued...
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SIIA writes to captive regulators to share 831(b) legislation concerns

The Self-Insurance Institute of America (SIIA) has written to state captive insurance...
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Signal Hill Petroleum 831(b) captives petition against IRS tax deficiency notice

Two Utah-domiciled captives making the 831(b) tax election have petitioned the Internal...
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Insurance For Tax Purposes

Kristen Hazel and Elizabeth Erickson, partners at law firm McDermott Will &...
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BEPS cannot be ignored and will impact domiciles – Ian Kilpatrick

Captive jurisdictions, both onshore and offshore, need to wake up to the...
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Captives face BEPS challenge from tax authorities

The Organisation for Economic Co-operation and Development (OECD) published its final package...
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US Tax Court rules in favour of RVI Guaranty

The United States Tax Court ruled yesterday that residual value insurance is...
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Clear guidance needed for 831(b) service providers – Mike DiMayo

Mike DiMayo, principal at Oxford Risk Management Group, has called on the...
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CICA updates 831(b) guidance

The Captive Insurance Companies Association (CICA) has published an “information statement” in...
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EU Commission performs u-turn on Guernsey’s tax cooperation

The European Union’s Commission has affirmed its view that Guernsey is a...
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831(b) family clampdown will surprise industry – Charles Lavelle

The Joint Committee on Taxation has proposed a complete ban on the...
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Airmic slams UK IPT rise

The United Kingdom’s risk management association, Airmic, has criticised the planned 50%...
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Poland removes Bermuda from blacklist as domicile fights back

Poland has removed Bermuda from its “blacklist” of countries that are deemed...
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Guernsey hits back after being placed on EU blacklist

Guernsey has published a rebuttal to the European Union after it was...
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Foreign Exchange Risk In Captives and IRS Scrutiny

The latest IRS challenge to classifying risk transfer as insurance for tax...
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HMRC poses difficult 25% DPT question over offshore captive profit

The United Kingdom’s tax authority has issued interim draft guidance concerning captive...
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Bill repealing Illinois self-procurement tax makes progress

Efforts to repeal the controversial Illinois self-procurement tax, signed into law last...
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Legislation introduced to increase 831(b) premium allowance

The United States’ House of Representatives and Senate have received legislation that...
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We will weigh in on 831(b) debate to avoid broad brush approach – Dennis Harwick

Dennis Harwick, president of the Captive Insurance Companies Association (CICA), believes it...
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Currency fluctuation cover not insurance, debate to begin

A Fortune 500 company has been told its utilisation of a captive...
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Illinois missing a trick by not chasing captive business

The legislature of Illinois could be missing out on increased economic activity...
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UPDATE: Senator amends Illinois bill to repeal captive tax

Senate Bill 1573, the proposal to repeal the controversial Illinois self-procurement tax...
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Bill to repeal controversial Illinois self-procurement tax proposed

Senator William Haine has introduced Senate Bill 1573 to the Illinois General...
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Dublin captives set for name change admin with new Companies Act imminent

Ireland’s Companies Act 2014 will come into effect on 1 June, 2015...
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The Debate: 831(b) Tax Election

On no topic is the American captive insurance industry more divided than the...
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Senate Finance Committee waters down 831(b) modification proposal

The United States’ Senate Finance Committee has dropped two proposed restrictions on...
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Our captives are insurance companies, regardless of IRS statements – North Carolina

The North Carolina Department of Insurance has insisted its own internal scrutiny...
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831(b) captives labelled a “charade” by IRS and adds to “Dirty Dozen” hit list

The United States’ Internal Revenue Service (IRS) has fired its latest warning...
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Controversial Illinois captive tax now law, but question marks remain

Captive owners headquartered in Illinois will be expected to begin paying premium...
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Illinois Chamber of Commerce rallies members against captive tax

Further pressure has been piled onto Illinois legislators to repeal Public Act...
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Feldman extends legal services to third-party managed captives

The affiliate law firm of Capstone Associated Services is to begin working...
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Luxembourg captives not implicated in aggressive multinational tax avoidance – Rod

Victor Rod, Luxembourg’s director of the Commissariat aux Aussurances, has told Captive...
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A new hope for Illinois captive tax veto after new Governor elected

Illinois-headquartered captive owners will be hoping the controversial 3.5% premium tax on...
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FiscalReps launches tax compliance product for USA

FiscalReps, an established insurance tax consultancy firm in Europe, will launch complianceDNA...
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Marsh: Most US captives not used for tax benefits

The majority of US captives are not generating tax benefits, according to...
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Hong Kong passes tax break for captives

Hong Kong's Legislative Council has passed the profit tax break for captives...
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NY captives face tax hike under proposed reform

Proposed corporate tax reform in New York is likely to raise taxes...
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HK needs mainland support to attract captives

The proposed profit tax break for captives in Hong Kong is a...
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Lawyers: RAC ruling is good news for captives

The majority decision last week by the U.S. Tax Court to allow...
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Hong Kong introduces Bill to lower tax for captives

Hong Kong has introduced a bill that aims to reduce the profits...
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Channel Islands sign U.S. IGA

Jersey, Guernsey and the Isle of Man individually signed Model I intergovernmental...
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Malta and Cayman sign TIEA

Captive domiciles Malta and the Cayman Islands signed a Tax Information Exchange...
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Wendy's captive wins Illinois court case

The captive belonging to the US chain of restaurants, Wendy’s, has been...
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Third party business into captives proves profitable

Extending the lines written through a captive in order to make writing...
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Guernsey signs UK IGA

Guernsey has signed an agreement with the UK on a package of...
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Isle of Man sign tax agreement with UK

The Isle of Man has become the first British dependency to sign...
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Up to eight states collecting self-procurement tax

Up to eight US states are collecting self-procurement tax under the Nonadmitted...
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Cameron: Crown Dependencies not tax havens

Prime Minister David Cameron has told Members of Parliament that it is...
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Overseas territories agree on G8 tax information deal

UK Prime Minister David Cameron has obtained agreement from Britain's overseas territories...
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Cannonier criticises Reuters

Bermudian Premier, Craig Cannonier, has objected to a Reuters headline which quoted...
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UK asks ‘tax havens’ to sign convention

UK prime minister, David Cameron has requested for the senior ministers of...
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Bermuda fears reinsurance bill will be passed without warning

The Association of Bermuda Insurers and Reinsurers (ABIR) have said that the...
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Swiss government set to allow banks to settle US tax disputes

The Swiss government is set to allow its banks to disclose client...
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Guernsey signs DTA with Luxembourg

Guernsey has signed a Double Taxation Arrangement (DTA) with Luxembourg. This is...
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Business tax change in IOM

The Isle of Man has withdrawn its attribution regime for individuals (ARI),...
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New Jersey licenses third captive from New York

New Jersey is hoping New Jersey-parented captives will redomicile in the state since it...
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Tax volatility to increase if UK CERs go

UK parented captives may face more volatility in taxes, depending on the...
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Bermuda tax law extension will provide ‘comfort and certainty’

The extension to existing tax exemptions for Bermuda companies outlined in the...
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Captive Review Dublin Report 2010

Captive Review Dublin Report 2010

A taxing New Year

A taxing New Year.PDF
Captive Review has published the 2017 Power 50 as a bespoke free-to-view e-reader report. By...
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The recent edition of American football’s championship Super Bowl game, occurring earlier this month, was...
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The rapid rate of technological development offers opportunities and hurdles for those working in the...
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The year-end captive statistics continue to roll in and, as ever, the usual debates and...
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Nigel Feetham, senior partner at Gibraltar law firm Hassans and an expert in cell company...
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