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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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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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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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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Institute for 831(b) microcaptives launches

The 831(b) Institute has launched in response to what it says is...
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IRS proposes new regulations targeting micro-captives

New proposals come after US court decisions ruling against the IRS’ use...
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Captive arrangements feature in IRS’ 2023 ‘dirty dozen’ list

Stamping out ‘abusive micro-captives’ a high priority enforcement area, IRS states  ...
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IRS names micro-captive fraud among ‘dirty dozen’ scams

The IRS has listed ‘abusive’ micro-captive insurance arrangements as one of the...
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CIC says IRS behaving like a “domestic terrorist”

CIC Services have said the Internal Revenue Service (IRS) is behaving like...
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Avrahami advisor Celia Clark sued by captive

Celia Clark, the advisor on the infamous Avrahami court case, is now...
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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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“IRS has viciously attacked captives”: CIC Services

Over the past week, the IRS has issued standard form letters to...
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CIC injunction granted; IRS enjoined from enforcing Notice 2016-66

A Tennessee court’s memorandum opinion and order has granted CIC Services’ motion...
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CIC file new injunctive relief motion

Captive manager CIC Services has filed a motion for injunctive relief with...
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Court rules in favour of IRS in Delaware summons case

The District of Delaware Court has ruled in favour of the IRS'...
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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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CIC victory against IRS

Last week a long-gestating court case reached its conclusion in the supreme...
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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 investigations into abusive tax schemes increases 57%

The Internal Revenue Service (IRS) investigations into abusive tax schemes, which includes...
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Microcaptives offered stricter settlements by IRS

The Internal Revenue Service (IRS) has offered a second, stricter, settlement deal...
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Microcaptive may owe IRS $2m

A microcaptive owner may still have to pay $2 million in tax...
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IRS expands captive enforcement

The Internal Revenue Service (IRS) has expanded its enforcement focus into "abusive"...
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The IRS vs Captives

On 22 July his year, almost two dozen captive organisations filed a...
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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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Microcaptive wins case against 40% IRS penalty

The United States Tax Court has ruled that a microcaptive should not...
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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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Law firm rejects IRS request for captive documents

In a brief filed to the Georgia Northern District court last week...
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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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Appeal filed in Reserve tax court case

An opening brief has been filed in the US Tenth Circuit Court of...
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IRS to audit micro captives

The IRS has established 12 new teams to audit what it deems...
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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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CIC Notice 2016-66 battle ‘far bigger’ than captives

CIC Services’ court battle with the Internal Revenue Service (IRS) is “far...
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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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CIC files petition against 2016-66 injunction denial

Tennessee-based captive manager CIC Services has filed a petition against an injunction...
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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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IRS starts campaign to monitor arm’s length pricing

The Internal Revenue Service’s (IRS) large business and international division (LB&I) has...
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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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Micro captives remain on IRS’ Dirty Dozen list

Micro captives will remain on the Internal Revenue Service’s (IRS) ‘Dirty Dozen’...
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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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CICA releases captive guidance document

The Captive Insurance Companies Association (CICA) has released a document advising professionals...
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Court ‘erroneous’ in Reserve case analysis – Capstone

Captive manager Capstone Associated Services has published its fourth commentary on the...
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Capstone continues Reserve case analysis, posts third response

Capstone Associated Services has posted its third commentary in response to the...
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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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Pinnacle rolls out new risk distribution measure

Actuarial consulting business Pinnacle has developed a new risk distribution measure following...
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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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Isle of Man and Malta sign CbC reporting agreements with IRS

The Isle of Man and Malta have joined Guernsey and Ireland as...
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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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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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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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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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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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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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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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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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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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How will BEPS affect captive insurance in the US?

No longer can America’s captive industry focus solely on compliance with the...
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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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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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Foreign Exchange Risk In Captives and IRS Scrutiny

The latest IRS challenge to classifying risk transfer as insurance for tax...
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CICA posts objection to IRS “active conduct” definition

The Captive Insurance Companies Association (CICA) has written to the Internal Revenue...
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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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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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Tax court in favour of Bermuda captive

The U.S. tax court has ruled that payments to Rent-a-Center (RAC) Inc’s...
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Dale Sagen, vice-president and business development leader with QBE Accident & Health, on how captive...
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Captive Review has featured hundreds of prevalent captive leaders over our 25 years of existence,...
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As Captive Review celebrates its 25th year in 2024, outgoing Captive Review publisher Nick Morgan...
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As Captive Review turns 25 this year, leaders from the industry share their thoughts on...
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