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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US Tax Court sides with IRS in latest small captive case

A United States Tax Court judge has ruled in favour of 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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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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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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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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Capstone weighs in on Avrahami decision

Texas-based Capstone Associated has published an extensive critique of the Avrahami captive...
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Risk Management Made Profitable

Jeremy P. Colombik, of Management Services International (MSI) and Richard M. Colombik, of...
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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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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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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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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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Tax and legal commentators in America’s captive insurance industry are not getting much respite, with...
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Captive Review reviews the test cases and pilots applying blockchain to captive and global insurance...
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Reserve Mechanical Corp. f.k.a. Reserve Casualty Corp. v. Commissioner of Internal Revenue (“Reserve”) was decided by...
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Elizabeth A. Erickson, Kristen E. Hazel, Thomas M. Jones, of McDermott Will & Emery LLP,...
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London-based Oliver Schofield, managing partner at risk and insurance consultancy RISCS, is an expert in...
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