IRS Archives - Captivereview

Wednesday, April 01, 2020

Lauren Ingram

IRS “insensitive and draconian” over micro captive letters

Tags: 831(B), Coronavirus, COVID-19, IRS, micro captive, SIIA

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

Tags: 831(B), Capstone, Coronavirus, COVID-19, IRS, pandemic, Reserve Mechanical Corp

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

Tags: 831(B), CIC Services, IRS, micro captive, Notice 2016-66

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

Tags: 831(B), Beecher Carlson, Bernie Sanders, CIC Services, CICA, Dave Provost, Heather McClure, Ian Davis, IRS, Jason Flaxbeard, Notice 2016-66, OU Medicine, VCIA, Vermont

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

Tags: Capstone, IRS, Reserve Mechanical Corp

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

Tags: IRS, micro captive, Notice 2016-66

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

Tags: 831(B), Derek Kaczmarek, Internal Revenue Service, IRS, Kaczmarek and Jojola, microcaptive, settlement, US Tax Court

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

Tags: 831(B), Internal Revenue Service, IRS, Mike DiMayo, oxford risk management, settlement offer

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

Tags: 831(B), Avrahami, Chuck Rettig, Internal Revenue Service, IRS, microcaptive, Reserve Mechanical, Syzygy, US Tax Court

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

Tags: CIC Services, IRS, Notice 2016-66, Sean King, Supreme Court

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

Tags: 831(B), captive owner, IRS, TPC Housing, Zack Deboi

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

Tags: CIC Services, injunction delay, IRS, Notice 2016-66, US Court of Appeals for the Sixth Circuit

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

Tags: 831(B), CIC, IRS, Jay Adkisson, Notice 2016-66, Sean King

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

Tags: arms length pricing, Captive insurance, IRS, OECD

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

Tags: 831(B), Ben Whitehouse, Butler Snow, Captive insurance, IRS, Syzygy

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

Tags: 831(B), Captive insurance, Highland Tank, IRS, Newport Re, Syzygy, US Risk Associates

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

Tags: Captive insurance, Dirty Dozen, IRS, micro captive, Tax

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’

Tags: 831(B), Captive insurance, defence, IRS, Tax

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

Tags: Captive insurance, Dan Towle, guidance, IRS, Reserve Mechanical, risk pooling, Tax

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

Tags: Avrahami, Capstone, Captive insurance, Court, erroneous, IRS, Reserve Mechanical Corp, Tax

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

Tags: Capstone, captive manager, commentary, government, IRS, Judge Kathleen Kerrigan, Reserve Mechanical, Tax, Tax Court

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’

Tags: 831(B), Artex, Arthur J Gallagher, Avrahami, Beecher Carlson, Captive insurance, IRS, Jason Flaxbeard, Reserve Mechanical

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

Tags: 831(B), Avrahami, Captive insurance, IRS, piranha, promoter audit, Tax

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

Tags: actuary, Captive, IRS, Pinnacle

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

Tags: 831(B), Dirty Dozen, IRS, Tax

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

Tags: BEPS, Guernsey, Ireland, IRS, Isle of Man, Malta, OECD, Tax

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

Tags: 831(B), IRS, Jeremy Colombik, MSI

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

Tags: 831(B), IRS, Notice 2016-66, Sean King

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

Tags: 831(B), Dirty Dozen, IRS, Tax

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

Tags: 831(B), IRS, Tax

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

Tags: 831(B), IRS, Notice 2016-66, SIIA

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

Tags: 831(B), IRS, Notice 2016-66, Tax

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

Tags: 831(B), Colorado, IRS, Notice 2016-66, Tax

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

Tags: 831(B), IRS, Jay Adkisson, Tax

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

Tags: 831(B), IRS, Regulation, SIIA, Tax

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

Tags: 831(B), Avrahami, Gary Osborne, IRS, Tax

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

Tags: 831(B), IRS, Tax

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?

Tags: BEPS, Crowe Horwath, Dan Kusaila, IRS, OECD

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

Tags: 831(B), CICA, IRS, Jay Adkisson, SIIA, Tax

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

Tags: 831(B), IRS, Signal Hill Petroleum, Tax

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

Tags: Foreign Exchange Risk, Frontrunner Captive, IRS, Randall Beckie, Tax

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

Tags: CICA, IRS, Regulation

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

Tags: Currency Fluctuation, IRS, Randall Beckie, Tax

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

Tags: IRS, Legal, Tax

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

Tags: IRS, Legal, RAC

The U.S. tax court has ruled that payments to Rent-a-Center (RAC) Inc’s...

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