Verve launches product covering captive defence costs

Includes coverage for fines and penalties related to IRS investigations arising from...
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How will Chevron decision impact IRS regs and micro-captives?

Experts in the micro-captive space talk to Captive Review about how the...
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IRS claims third micro-captive court win of 2024

Victory in Patel vs Commissioner is seventh consecutive IRS win, as “wholly...
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How will “problematic” Greenbook proposals hurt 831(b) industry?

US lawmakers fire another arrow at the micro-captive sector, but how damaging...
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US Treasury’s ‘Green Book’ proposes new 831(b) ownership rules

Treasury states “a statutory remedy” is needed to address “the pervasiveness of...
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IRS scrutiny sees 56 Nevada 831(b) captives close in 2023

Nevada’s Division of Insurance estimates that of its 71 surrendered captive licences,...
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Oklahoma reveals 2023 captive figures

Of Oklahoma’s 59 captives and cell/series captives, 16 of them took the...
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Utah welcomes innovative new captives amid “chilling effect” of IRS scrutiny

While Utah captive director Travis Wegkamp says IRS scrutiny has had “chilling...
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IRS wins sixth micro-captive court case

Tax Court’s opinion in Swift vs Commissioner found two St Kitts and...
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What does latest IRS court victory mean for 831(b) captives?

Captive insurance tax experts speak to Captive Review about Keating vs Commissioner...
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IRS wins latest 831(b) microcaptive court case

US Tax Court found Anguilla-based captive Risk Retention Ltd was not “insurance...
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House Ways and Means Committee backs microcaptives in letter to IRS

The committee wrote to IRS commissioner Daniel Werfel giving their "strong support"...
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Captive owner Q&A: David Findlay, Lake City Bank

The IRS’ proposals for identifying certain 831(b)-electing captives as ‘listed transactions’ have...
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Community bank captive will “likely dissolve” under IRS’ 831(b) proposals

The owner of Lake City Bank’s captive tells Captive Review why the...
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Half time report: signs of a captive growth slowdown as IRS scrutiny bites

Property is the main driver of captive growth in the first half...
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Delaware H1 captive dissolutions almost entirely 831(b) companies

dollar dissolve
Other 831(b)-electing captives are choosing not to renew policies until the IRS...
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IRS 831(b) micro-captive proposals: what to expect next?

In the wake of vehement opposition through a comments period and public...
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Federal judge vacates IRS Notice 2016-66, calls it “arbitrary and capricious”

The Internal Revenue Service (IRS) has lost its bid to enforce its...
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IRS targeting “abusive” microcaptives with 200 more attorneys

The Internal Revenue Service (IRS) has furthered its crackdown on "abusive" microcaptives...
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Clark launches legal challenge over Avrahami penalties

The infamous Avrahami captive insurance case is back in court as the...
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Microcaptives back on IRS Dirty Dozen list

The Internal Revenue Service (IRS) has once again featured microcaptives on its...
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IRS targets microcaptive “promoters” with new investigations office

The Internal Revenue Service (IRS) has announced the establishment of the Office...
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Are the IRS’s new captive insurance settlement terms worth it?

By Charlie Ruchelman and Ben Eisenstat Caplin and Drysdale The IRS does...
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BREAKING: Microcaptive critic named assistant secretary for tax policy

Economist Mark J. Mazur has been named assistant secretary for tax policy...
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Are the IRS settlement terms worth it?

By Charlie Ruchelman and Ben Eisenstat The IRS does not like Section...
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IRS will consider “additional guidance” for micro captives

The Internal Revenue Service (IRS) has said it may consider additional guidance...
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IRS expands captive enforcement

The Internal Revenue Service (IRS) has expanded its enforcement focus into "abusive"...
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Artex class action dismissed by judge

An appeal from members of a class action suit filed against Artex,...
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Captives: What you need to know this week

Welcome to another week in the captive world, and our new week...
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US Senator asks Treasury to suspend IRS microcaptive investigation

United States Senator Cory Gardner has written to the US Treasury to...
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‘Majority of microcaptive cases’ examined are abusive: IRS

The Internal Revenue Service (IRS) has stated that the "majority" microcaptive cases...
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Judge rules in Arsenal-Jade Risk case

A judge has ruled in favour of the former owner of Jade...
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IRS sends more letters to micro captives

The United States Internal Revenue Service (IRS) has sent another batch of...
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EXCLUSIVE: Captive organisations file brief for IRS Supreme Court case

EXCLUSIVE: Almost two dozen captive organisations will today file a brief with...
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Micro captives removed from IRS ‘Dirty Dozen’ list

The United States Internal Revenue Service (IRS) has unveiled its "dirty dozen"...
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EXCLUSIVE: IRS takes Delaware Department of Insurance to court

The US Internal Revenue Service (IRS) has taken the Delaware Department of...
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Supreme Court to hear CIC Services IRS case

The United States Supreme Court has agreed to hear CIC Services' case...
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Covid-19, the IRS and captives

By Nate Reznicek We find ourselves in an interesting time. The threat...
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IRS “insensitive and draconian” over micro captive letters

The Self-Insurance Institute of America (SIIA) has written to the Internal Revenue...
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Coronavirus shows IRS was wrong about microcaptives

The coronavirus pandemic has shown how the Internal Revenue Service (IRS) and...
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Micro captives, mega issues

Last month, the Internal Revenue Service (IRS) announced that it has established...
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US news attacks captives and links to Bernie Sanders

Last Wednesday US news website The Daily Beast described captive insurance companies...
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IRS settlement details revealed

Captives that have been offered a settlement by the Internal Revenue Service...
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IRS settlement offer a ‘non-event’, says Oxford RMG

The Internal Revenue Service’s (IRS) settlement offer is a non-event in the...
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Captives under audit offered IRS settlement

The Internal Revenue Service (IRS) has offered 200 captives currently under audit...
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Exclusive: 831(b) lawsuit defendants leave Artex

Three Artex employees have left the company, Captive Review can reveal. Jeremy...
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831(b)’s a ‘legit risk management mechanism’, says captive owner

Captive insurance companies electing to operate under the 831(b) tax rules have...
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Artex motion to dismiss ‘civil conspiracy’ suit granted

Artex’s joint motion to dismiss a class action suit alleging it promoted...
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North Carolina licences five new captives

North Carolina has licensed five new captives so far this year, filings...
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Avrahami’s complain of ‘flawed insurance product’ in latest class action suit

The Avrahami’s and their captive Feedback Insurance Company have filed a class...
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CIC denied injunction on Notice 2016-66

Tennessee-based captive manager CIC Services has been denied an injunction delay on...
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Q&A: Captive Alternatives’ David Kirkup on Syzygy

Last month, Captive Review reported that the US Tax Court had ruled...
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Whitehouse: Case for 831(b)s is improving

The case for 831(b) captives is improving despite the latest Internal Revenue...
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IRS prevails in Syzygy 831(b) case

The US Tax Court has ruled in favour of the Internal Revenue...
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Frontrunner Captive Management: Captives must ‘re-inspect their defences’

It is time for captives to “re-inspect their defences”, as the IRS...
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Tennessee captive market performing at ‘healthy rate’

The captive insurance industry in Tennessee has performed at a “very healthy...
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Artex, Gallagher case could ‘taint the industry’

The class action lawsuit against a group including Artex and Arthur J...
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831(b) lawsuits ‘like school of piranhas’ – Jay Adkisson

Class action lawsuits against captives found to not be in compliance with...
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Artex, Arthur J Gallagher among group accused of 831 (b) captive ‘conspiracy’

A group of plaintiffs have filed a class action lawsuit against a...
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831(b) limit to remain unchanged for 2019

The limit on annual premium written by captives wishing to make the...
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Risk Strategies “comfortable” with 831(b) association after Oxford acquisition

Mike Christian, founder and CEO of Risk Strategies, has told Captive Review...
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US Tax Court: A Pipeline of Small Captive Cases

Charles Lavelle, senior partner at Bingham Greenebaum Doll LLP, provides Captive Review...
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Avrahami to become go-to guide for Tax Court cases concerning small captives

In light of Judge Kathleen Kerrigan’s continued citing of Avrahami in her...
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Reserve Mechanical has “stronger fact patterns than Avrahami”, but outcome “not shocking”

Tax and captive insurance professionals have provided their initial reaction to the...
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Avrahami had a “chilling effect” on US captive industry – Steve Kinion

A combination of the Avrahami ruling and the PATH Act led to...
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Small captives in transition and growth is slowing – Brady Young

The growth in America’s smaller captive numbers may be slowing down, but...
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PATH Act clarifications included in Congress’ federal spending bill

Three key areas of the Protecting Americans from Tax Hikes Act of...
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831(b) captives remain on IRS’ ‘Dirty Dozen’ list

Captive insurance companies making the 831(b) tax election will remain under heavy...
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CICA restructures small captives task force

The Captive Insurance Companies Association (CICA) has updated its Small Captives Task...
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Practical Concerns for 831(b) Captive Owners Post Avrahami

Captive owners making the 831(b) tax election are reassessing their structures and...
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First inflation adjustment triggered for 831(b)s

The first adjustment to the premium limit for 831(b) electing captives in...
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831(b) owners seeking second opinion on structures

Businesses that own 831(b) captives are contacting captive managers and other third-party...
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Celia Clark responds to latest Avrahami motion

The Avrahamis lost its bid for two motions of reconsideration in November...
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Judge Holmes criticises “sloppy” policy language in latest Avrahami exchange

The Avrahami’s move for reconsideration of two findings of fact has been...
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Lessons Learned from Avrahami

Peter Johnson, senior actuarial consultant and property & casualty practice lead at Spring...
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Connecticut keen to “revive” 831(b) reputation – Michael Maglaras

Michael Maglaras, chairman of the Connecticut Captive Insurance Association, believes it is...
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CIC Services considering options after Notice 2016-66 defeat

CIC Services and Ryan, LLC have had their case against the Internal...
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Exclusive: Celia Clark responds to Avrahami criticism

Celia Clark, the captive manager of Feedback Insurance Company and a former...
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The Avrahami Record, by Celia Clark

Captive Review has reported extensively on the Avrahami v Commissioner case, including...
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Avrahami manager to close captive practice

Clark & Gentry, PLLC, the firm responsible for structuring and managing the...
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Avrahami – The Wider Implications

What does the future hold for larger captives in the post-Avrahami-decision world? ...
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ABA appoints John Dies to captive committee

John Dies, alliantgroup’s managing director of tax controversy, has joined the American...
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Capstone weighs in on Avrahami decision

Texas-based Capstone Associated has published an extensive critique of the Avrahami captive...
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Exclusive: Avrahami actuary responds to US Tax Court criticism

The actuary that priced the premium for Feedback Insurance Company, the captive...
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AVRAHAMI v. COMMISSIONER – The Details

Charles J. Lavelle, Brett J. Miller and Ross D. Cohen, of Bingham...
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Final Word: How should a captive price terrorism?

Tammi Brown and Doug Butler, of MIJS, discuss terrorism as an insurable...
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AVRAHAMI: Opinion will embolden the IRS, settlements more expensive

The Internal Revenue Service will be “emboldened” by their win in the...
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AVRAHAMI: Industry distances itself from “negative facts”

Industry players have expressed little surprise at the outcome of the Avrahami...
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AVRAHAMI: Tax Court slams promoter, premiums “utterly unreasonable”

The United States Tax Court has lambasted the promoter who sold and...
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AVRAHAMI: Premium NOT insurance, 831(b) election invalid – US Tax Court

The United States Tax Court has ruled in favour of the Internal...
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Treasury snubs Notice 2016-66 in interim report

Notice 2016-66 has not been included on the Treasury’s interim list of...
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Request to include Notice 2016-66 in Trump report

The Self-Insurance Institute of America (SIIA) has written to the Treasury requesting...
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13 states requesting Form 8886 filings from 831(b) captives

Captive managers and material advisors to captives making the 831(b) tax election...
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Captives Receive Great News, IRS loses on Substance over Form

Richard M. Colombik, of TLS Marketing and Management Services, LLC , and Jeremy P....
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Citadel Risk launches Tennessee cell company, targets 831(b) business

A new incorporated cell company has been formed in Tennessee by Citadel...
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Notice 2016-66 injunction denied

An attempt to get a preliminary injunction against the 1 May deadline...
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Common Ground With The IRS?

The captive industry has reacted with scorn to the IRS’ attitude towards...
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IRS is not acting in good faith – Sean King

Sean King, the captive manager behind a lawsuit seeking to postpone and...
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CIC Services files second lawsuit against IRS

CIC Services has been joined by Ryan, LLC in filing a lawsuit...
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Federal district court upholds attorney-client privilege claim

The federal district court has agreed with the original decision of the...
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The possible ramifications of Notice 2016-66 on the Path Act

Jeremy Colombik is president of Management Services International (MSI). MSI currently manages...
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Connecticut commissioner set to investigate microcaptives

Connecticut’s insurance commissioner is set to embark on a study of those...
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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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Technical corrections to PATH Act expected in Congress

The United States’ smaller captive industry is optimistic that groundwork laid with...
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SIIA asks IRS to suspend Notice 2016-66, cites Trump administration

The Self-Insurance Institute of America (SIIA) has criticised the “paperwork intensive approach”...
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Vermont makes play for smaller captives with new legislation

The Vermont Captive Insurance Association (VCIA) has put forward a captive bill...
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Uncertainty to remain and scrutiny to increase on 831(b)s – Jason Flaxbeard

Jason Flaxbeard, captive practice leader at Beecher Carlson, does not believe 2017...
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Revealed: The 2016 Captive Review ERC Pioneers

Captive Review has published the second Enterprise Risk Captive (ERC) Pioneers list,...
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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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News Analysis: Tax Opinion Analyses 831(b) Options

A leading tax attorney has published three tax opinions discussing Notice 2016-66...
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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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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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SIIA to request 831(b) reporting extension, Tarter bullish over new formations

The Self-Insurance Institute of America (SIIA) will write to the Internal Revenue...
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IRS includes DoL exemption in 831(b) notice

Captive insurance companies that make the 831(b) tax election, but have successfully...
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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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Premium increases on backburner as owners seek 831(b) compliance

Managers and captive owners using the 831(b) tax election are prioritising business...
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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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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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831(b) rise to $2.2m peaking risk managers’ interest – JLT Towner

The 831(b) tax election, cell captives and solutions for the middle market...
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Capstone adds lawyer to support 831(b) restructurings

The Feldman Law Firm LLP, the affiliated law firm of Houston-based captive...
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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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Why is ERC good for you?

Enterprise risk captives, or ERCs, are booming business in the United States, but...
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Puerto Rico expecting dramatic growth in micro-captives

David Kirkup, COO and CFO of insurance manager Captive Alternatives, has told...
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Captive Review August Edition

What do Dennis Harwick, David Cameron and Gordon Rowell have in common?...
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Premium increase is validation of micro-captive industry – Les Boughner

Les Boughner, chairman of Advantage Insurance Holdings’ business insurance division, believes changes...
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831(b) re-structuring activity will take place in final months of 2016 – Steve Kinion

Steve Kinion, Delaware’s captive regulator, has told Captive Review he is expecting...
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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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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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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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Small captives have a shorter life span – David Snowball

Utah’s captive insurance regulator, David Snowball, has told Captive Review the majority...
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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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Revealed: The 2015 Captive Review ERC Pioneers

The first Enterprise Risk Captive (ERC) Pioneers list has been published by...
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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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Industry rallying to fight “harmful” 831(b) legislation

America’s captive insurance industry, led by the Self Insurance Institute of America...
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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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“Dirty Dozen” label should be a wake-up call – Dana Sheridan

Enterprise risk captives place on the Internal Revenue Service’s “Dirty Dozen” list...
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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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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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Captive Review June Edition

A re-occurring battle for risk and insurance managers can often be justifying...
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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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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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We’d support a Europe equivalent to the 831(b) – Willis

Senior figures at Willis Global Captive Practice have told Captive Review they...
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Enterprise Risk Captive Report 2015

Captive Review’s first Enterprise Risk Captive Report analyses the key issues surrounding the...
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Make sure 831(b) captives are true insurance vehicles – Smith

Rich Smith, president of the Vermont Captive Insurance Association (VCIA), has called...
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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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EU domiciles should offer an equivalent to the US 831(b) – Urs Neukomm

Urs Neukomm, director of strategic solutions for corporates at Swiss Re, has...
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News Feature: American inspiration for Europe’s mid-market?

As the US captive industry profits from the rapid growth in mid-market...
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Bahamas forecast as next hub for 831(b)’s

The Bahamas is forecast to be the next major domiciles for 831(b)...
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PCC’s more flexible than 831(b) micro captives

Protected cell captives (PCC) are an attractive alternative for smaller parent companies,...
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Bahamas 'risen from extinction' in captive market

US-based The Strauss Law Firm LLC said the Bahamas has "risen from...
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The IRS is biding its time by taking on micro-captives and will eventually refocus on...
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Randy Sadler, principal at CIC Services, discusses why captive professionals should be more strongly considering...
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Guy Carpenter’s Rick Hartmann, senior vice president, Treaty Broking, explains why – and how –...
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Ian-Edward Stafrace of Atlas Insurance PCC, a FinanceMalta member, explores how Malta’s innovative protected cell...
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