Thursday, April 07, 2022
Ross Law

CIC says IRS behaving like a “domestic terrorist”

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CIC Services have said the Internal Revenue Service (IRS) is behaving like...
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Thursday, February 24, 2022
Lauren Ingram

Avrahami advisor Celia Clark sued by captive

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Celia Clark, the advisor on the infamous Avrahami court case, is now...
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Sunday, January 23, 2022
Lauren Ingram

IRS targeting “abusive” microcaptives with 200 more attorneys

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The Internal Revenue Service (IRS) has furthered its crackdown on "abusive" microcaptives...
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Tuesday, December 07, 2021
Lauren Ingram

Clark launches legal challenge over Avrahami penalties

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The infamous Avrahami captive insurance case is back in court as the...
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Tuesday, November 16, 2021
Lauren Ingram

“IRS has viciously attacked captives”: CIC Services

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Over the past week, the IRS has issued standard form letters to...
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Wednesday, September 22, 2021
Ross Law

CIC injunction granted; IRS enjoined from enforcing Notice 2016-66

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A Tennessee court’s memorandum opinion and order has granted CIC Services’ motion...
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Monday, August 09, 2021
Ross Law

CIC file new injunctive relief motion

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Captive manager CIC Services has filed a motion for injunctive relief with...
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Monday, July 26, 2021
Ross Law

Court rules in favour of IRS in Delaware summons case

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The District of Delaware Court has ruled in favour of the IRS'...
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Monday, July 05, 2021
Lauren Ingram

Microcaptives back on IRS Dirty Dozen list

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The Internal Revenue Service (IRS) has once again featured microcaptives on its...
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Tuesday, May 25, 2021
Ross Law

CIC victory against IRS

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Last week a long-gestating court case reached its conclusion in the supreme...
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Tuesday, April 20, 2021
Ross Law

IRS targets microcaptive “promoters” with new investigations office

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The Internal Revenue Service (IRS) has announced the establishment of the Office...
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Thursday, February 11, 2021
Lauren Ingram

Are the IRS’s new captive insurance settlement terms worth it?

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By Charlie Ruchelman and Ben Eisenstat Caplin and Drysdale The IRS does...
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Monday, January 25, 2021
Lauren Ingram

BREAKING: Microcaptive critic named assistant secretary for tax policy

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Economist Mark J. Mazur has been named assistant secretary for tax policy...
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Tuesday, January 12, 2021
Lauren Ingram

Are the IRS settlement terms worth it?

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By Charlie Ruchelman and Ben Eisenstat The IRS does not like Section...
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Thursday, January 07, 2021
Lauren Ingram

IRS will consider “additional guidance” for micro captives

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The Internal Revenue Service (IRS) has said it may consider additional guidance...
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Monday, November 23, 2020
Lauren Ingram

IRS investigations into abusive tax schemes increases 57%

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The Internal Revenue Service (IRS) investigations into abusive tax schemes, which includes...
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Monday, October 26, 2020
Lauren Ingram

Microcaptives offered stricter settlements by IRS

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The Internal Revenue Service (IRS) has offered a second, stricter, settlement deal...
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Thursday, October 08, 2020
Lauren Ingram

Microcaptive may owe IRS $2m

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A microcaptive owner may still have to pay $2 million in tax...
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Friday, October 02, 2020
Lauren Ingram

IRS expands captive enforcement

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The Internal Revenue Service (IRS) has expanded its enforcement focus into "abusive"...
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Thursday, September 17, 2020
Lauren Ingram

The IRS vs Captives

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On 22 July his year, almost two dozen captive organisations filed a...
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Monday, September 14, 2020
Lauren Ingram

Artex class action dismissed by judge

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An appeal from members of a class action suit filed against Artex,...
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Monday, September 07, 2020
Lauren Ingram

Captives: What you need to know this week

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Welcome to another week in the captive world, and our new week...
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Friday, September 04, 2020
Lauren Ingram

US Senator asks Treasury to suspend IRS microcaptive investigation

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United States Senator Cory Gardner has written to the US Treasury to...
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Tuesday, September 01, 2020
Lauren Ingram

‘Majority of microcaptive cases’ examined are abusive: IRS

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The Internal Revenue Service (IRS) has stated that the "majority" microcaptive cases...
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Thursday, August 20, 2020
Lauren Ingram

Microcaptive wins case against 40% IRS penalty

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The United States Tax Court has ruled that a microcaptive should not...
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Sunday, August 16, 2020
Lauren Ingram

Captives: what you need to know this week

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Welcome to another week in the captive world, and our new week...
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Sunday, August 16, 2020
Lauren Ingram

Law firm rejects IRS request for captive documents

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In a brief filed to the Georgia Northern District court last week...
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Monday, August 10, 2020
Lauren Ingram

IRS sends more letters to micro captives

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The United States Internal Revenue Service (IRS) has sent another batch of...
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Wednesday, July 22, 2020
Lauren Ingram

EXCLUSIVE: Captive organisations file brief for IRS Supreme Court case

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EXCLUSIVE: Almost two dozen captive organisations will today file a brief with...
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Friday, July 17, 2020
Lauren Ingram

Micro captives removed from IRS ‘Dirty Dozen’ list

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The United States Internal Revenue Service (IRS) has unveiled its "dirty dozen"...
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Tuesday, June 23, 2020
Lauren Ingram

EXCLUSIVE: IRS takes Delaware Department of Insurance to court

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The US Internal Revenue Service (IRS) has taken the Delaware Department of...
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Tuesday, May 05, 2020
Lauren Ingram

Supreme Court to hear CIC Services IRS case

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The United States Supreme Court has agreed to hear CIC Services' case...
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Wednesday, April 29, 2020
Lauren Ingram

Covid-19, the IRS and captives

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By Nate Reznicek We find ourselves in an interesting time. The threat...
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Wednesday, April 01, 2020
Lauren Ingram

IRS “insensitive and draconian” over micro captive letters

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The Self-Insurance Institute of America (SIIA) has written to the Internal Revenue...
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Wednesday, March 25, 2020
Lauren Ingram

Coronavirus shows IRS was wrong about microcaptives

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The coronavirus pandemic has shown how the Internal Revenue Service (IRS) and...
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Friday, March 20, 2020
Lauren Ingram

Micro captives, mega issues

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Last month, the Internal Revenue Service (IRS) announced that it has established...
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Tuesday, March 03, 2020
Lauren Ingram

US news attacks captives and links to Bernie Sanders

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Last Wednesday US news website The Daily Beast described captive insurance companies...
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Monday, March 02, 2020
Lauren Ingram

Appeal filed in Reserve tax court case

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An opening brief has been filed in the US Tenth Circuit Court of...
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Wednesday, February 05, 2020
Lauren Ingram

IRS to audit micro captives

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The IRS has established 12 new teams to audit what it deems...
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Thursday, September 26, 2019
Fraser Irving

IRS settlement details revealed

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Captives that have been offered a settlement by the Internal Revenue Service...
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Thursday, September 19, 2019
Fraser Irving

IRS settlement offer a ‘non-event’, says Oxford RMG

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The Internal Revenue Service’s (IRS) settlement offer is a non-event in the...
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Tuesday, September 17, 2019
Fraser Irving

Captives under audit offered IRS settlement

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The Internal Revenue Service (IRS) has offered 200 captives currently under audit...
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Monday, September 16, 2019
Fraser Irving

CIC Notice 2016-66 battle ‘far bigger’ than captives

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CIC Services’ court battle with the Internal Revenue Service (IRS) is “far...
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Friday, August 23, 2019
Fraser Irving

831(b)’s a ‘legit risk management mechanism’, says captive owner

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Captive insurance companies electing to operate under the 831(b) tax rules have...
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Friday, July 12, 2019
Fraser Irving

CIC files petition against 2016-66 injunction denial

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Tennessee-based captive manager CIC Services has filed a petition against an injunction...
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Tuesday, May 28, 2019
Fraser Irving

CIC denied injunction on Notice 2016-66

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Tennessee-based captive manager CIC Services has been denied an injunction delay on...
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Tuesday, April 23, 2019
Fraser Irving

IRS starts campaign to monitor arm’s length pricing

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The Internal Revenue Service’s (IRS) large business and international division (LB&I) has...
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Friday, April 12, 2019
Fraser Irving

Whitehouse: Case for 831(b)s is improving

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The case for 831(b) captives is improving despite the latest Internal Revenue...
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Thursday, April 11, 2019
Fraser Irving

IRS prevails in Syzygy 831(b) case

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The US Tax Court has ruled in favour of the Internal Revenue...
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Wednesday, March 20, 2019
Fraser Irving

Micro captives remain on IRS’ Dirty Dozen list

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Micro captives will remain on the Internal Revenue Service’s (IRS) ‘Dirty Dozen’...
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Monday, March 18, 2019
Fraser Irving

Frontrunner Captive Management: Captives must ‘re-inspect their defences’

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It is time for captives to “re-inspect their defences”, as the IRS...
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Thursday, January 31, 2019
Fraser Irving

CICA releases captive guidance document

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The Captive Insurance Companies Association (CICA) has released a document advising professionals...
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Tuesday, January 15, 2019
Fraser Irving

Court ‘erroneous’ in Reserve case analysis – Capstone

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Captive manager Capstone Associated Services has published its fourth commentary on the...
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Friday, December 21, 2018
Fraser Irving

Capstone continues Reserve case analysis, posts third response

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Capstone Associated Services has posted its third commentary in response to the...
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Monday, December 17, 2018
Fraser Irving

Artex, Gallagher case could ‘taint the industry’

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The class action lawsuit against a group including Artex and Arthur J...
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Wednesday, December 12, 2018
Fraser Irving

831(b) lawsuits ‘like school of piranhas’ – Jay Adkisson

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Class action lawsuits against captives found to not be in compliance with...
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Wednesday, November 28, 2018
Fraser Irving

Pinnacle rolls out new risk distribution measure

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Actuarial consulting business Pinnacle has developed a new risk distribution measure following...
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Tuesday, March 20, 2018
Richard Cutcher

831(b) captives remain on IRS’ ‘Dirty Dozen’ list

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Captive insurance companies making the 831(b) tax election will remain under heavy...
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Tuesday, July 25, 2017
Richard Cutcher

Isle of Man and Malta sign CbC reporting agreements with IRS

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The Isle of Man and Malta have joined Guernsey and Ireland as...
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Wednesday, June 07, 2017
Captive Review

Captives Receive Great News, IRS loses on Substance over Form

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Richard M. Colombik, of TLS Marketing and Management Services, LLC , and Jeremy P....
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Monday, April 10, 2017
Richard Cutcher

IRS is not acting in good faith – Sean King

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Sean King, the captive manager behind a lawsuit seeking to postpone and...
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Thursday, February 16, 2017
Richard Cutcher

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

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The Internal Revenue Service has published its annual Dirty Dozen list of...
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Monday, February 13, 2017
Richard Cutcher

Exclusive: MIJS court victory against IRS a ‘game changer’ in 831(b) fight

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A Summons issued by the Internal Revenue Service (IRS) to Moore Ingram...
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Wednesday, February 01, 2017
Richard Cutcher

SIIA asks IRS to suspend Notice 2016-66, cites Trump administration

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The Self-Insurance Institute of America (SIIA) has criticised the “paperwork intensive approach”...
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Tuesday, January 03, 2017
Richard Cutcher

IRS extends Notice 2016-66 deadline by 90 days

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Captive managers and material advisors working with captives making the 831(b) tax...
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Tuesday, November 22, 2016
Richard Cutcher

Colorado Senator first to lobby IRS over “burdensome” Notice 2016-66

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A Democratic senator from Colorado has written to the Commissioner of the...
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Friday, November 04, 2016
Richard Cutcher

Industry slams ‘deliberately bad timing’ of IRS’ latest 831(b) Notice

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The Internal Revenue Service (IRS) intentionally waited until the busy season to...
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Tuesday, October 25, 2016
Richard Cutcher

SIIA and 15 captive associations lobby for Federal guidance on 831(b) rules

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The Self-Insurance Institute of America (SIIA), along with 15 state captive insurance...
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Tuesday, July 26, 2016
Richard Cutcher

IRS losing Avrahami could create open season for 831(b)s – Gary Osborne

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Gary Osborne, president of USA Risk Group, believes the Internal Revenue Service...
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Wednesday, April 13, 2016
Richard Cutcher

US Tax Court sides with IRS in pending micro-captive case

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The Internal Revenue Service (IRS) has won an early victory in its...
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Thursday, February 04, 2016
Captive Review

How will BEPS affect captive insurance in the US?

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No longer can America’s captive industry focus solely on compliance with the...
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Tuesday, December 22, 2015
Richard Cutcher

Industry schism is losing the IRS fight over small captives – Jay Adkisson

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The lack of unity within the United States’ captive insurance industry has...
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Wednesday, November 25, 2015
Richard Cutcher

Signal Hill Petroleum 831(b) captives petition against IRS tax deficiency notice

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Two Utah-domiciled captives making the 831(b) tax election have petitioned the Internal...
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Monday, May 18, 2015
Captive Review

Foreign Exchange Risk In Captives and IRS Scrutiny

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The latest IRS challenge to classifying risk transfer as insurance for tax...
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Monday, May 11, 2015
Richard Cutcher

CICA posts objection to IRS “active conduct” definition

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The Captive Insurance Companies Association (CICA) has written to the Internal Revenue...
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Wednesday, April 08, 2015
Richard Cutcher

Currency fluctuation cover not insurance, debate to begin

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A Fortune 500 company has been told its utilisation of a captive...
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Tuesday, January 21, 2014
Richard Cutcher

Lawyers: RAC ruling is good news for captives

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The majority decision last week by the U.S. Tax Court to allow...
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Wednesday, January 15, 2014
Richard Cutcher

Tax court in favour of Bermuda captive

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The U.S. tax court has ruled that payments to Rent-a-Center (RAC) Inc’s...
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Features
The new cyber war
Analysts are warning that spill over from the Russian invasion of Ukraine is resulting in...
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Captive Owner Profile: Udo Kappes
Udo Kappes, Head of P&C, Employee Lines, Reinsurance at Airbus Insurance Risk Management, and Chairman...
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Captives in a hard market
Paul Woehrmann and Pieter Nyssen from Zurich analyse the range of alternative risk transfer solutions...
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The 2022 captive outlook
As we are all stridently aware, the onset of the coronavirus pandemic in the western...
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Captive Owner Profile: Denya Feng, Cummins
Deyna Feng, director of captive programs at Cummins, discusses the role their captive plays in...
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