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Downs Rachlin Martin PLLC

Captive Insurance Update | Issue 2 | 2025

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Every year, the members of the Vermont Captive Insurance Association’s legislative committee and the Vermont Department of Financial Regulation (the “DFR”) work to improve Vermont’s captive insurance laws and regulations....more

McDermott Will & Schulte

Weekly IRS Roundup January 3 – January 6, 2023

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 3, 2023 – January 6, 2023...more

Holland & Knight LLP

Takeaways from the Tax Court's First Micro-Captive Insurance Ruling

Holland & Knight LLP on

• The U.S. Tax Court recently ruled in Avrahami v. Commissioner, the first litigated Tax Court case involving an 831(b) captive insurance company. • The Tax Court held that two of the key factors that define "insurance"...more

McDermott Will & Schulte

SALT Implications of Final Section 385 Debt-Equity Regulations

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The recently released final regulations under Internal Revenue Code Section 385, addressing the circumstances under which related company debt will be classified as equity for federal income tax purposes, will have a...more

Eversheds Sutherland (US) LLP

Required Summer Reading: Guidance Issued on the Tax Treatment of Guaranteed Minimum Benefit Hedges and Identified Mixed Straddles

Eversheds Sutherland (US) LLP on

The Treasury and the IRS offered two pieces of highly anticipated guidance on July 18 that are particularly relevant to the life insurance industry. ...more

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