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Internal Revenue Service Internal Revenue Code (IRC) Insurance Industry

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Womble Bond Dickinson

Micro-Captive Reportable Transaction Deadline Effectively Extended

Womble Bond Dickinson on

On Friday, April 11, 2025, the Internal Revenue Service issued Notice 2025-24 (the “Notice”), which waives applicable penalties under the Internal Revenue Code to participants in, and material advisors to, reportable...more

Gerald Nowotny - Law Office of Gerald R....

Old Days – Memories of Equity Split Dollar in the Post-Loper Bright Era

This article focuses on the impact of the U.S. Supreme Court in Loper Bright Enterprises v. Raimondo, 603 U.S. (2024) and how it might apply to Split Dollar life insurance and possibly resurrect one of my favorite life...more

Womble Bond Dickinson

Micro-captive Insurance Reportable Transactions and the Reporting Requirements

Womble Bond Dickinson on

Certain micro-captive transactions are back to being reportable. On January 14, 2025, the Treasury Department and the Internal Revenue Service (“IRS”) published final regulations (the “Regulations”) that named some...more

Gerald Nowotny - Law Office of Gerald R....

Las Mañanitas

Recently (January 15th) I celebrated my sixty fifth birthday. Where did the time go? If my East German father Willy Wolfgang Nowotny were still with us, I could hear him say, “Too soon old, too late smart.” While I was never...more

Levenfeld Pearlstein, LLC

Another Attack on Private Placement Life Insurance

The use of private placement life insurance (PPLI) by high-net-worth individuals has generated considerable controversy over the years, with proponents arguing that it is a proper use of existing laws that provide many of the...more

Carlton Fields

Tax Court Upholds IRS Decision That Premiums Paid to Microcaptive Insurance Companies Did Not Qualify for Tax Deductions

Carlton Fields on

The U.S. Tax Court recently upheld a determination by the IRS that premium payments to certain microcaptives could not be deducted for tax purposes because the premium payments were not actually for “insurance.”...more

McDermott Will & Emery

Weekly IRS Roundup February 13 – February 17, 2023

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 13, 2023 – February 17, 2023. ...more

McDermott Will & Emery

Weekly IRS Roundup January 3 – January 6, 2023

McDermott Will & Emery on

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

Gerald Nowotny - Law Office of Gerald R....

All in the Family – Introducing Family-Owned Life Insurance™ (aka FOLI)

Perhaps you are tired of reading that I grew up in the Panama Canal Zone, but it is one of the last bastions of American colonialism. Personally, I do not like the word “colonialism” because it inevitably conjures up negative...more

Downs Rachlin Martin PLLC

Captive Insurance Update | Spring Edition | 2021 - A summary of state and federal developments in the captive insurance industry

The measures taken by the Vermont Department of Financial Regulation (the “DFR”) in 2020 in response to the COVID-19 pandemic have been extended through 2021. These include a recognition that in-person board meetings in...more

Faegre Drinker Biddle & Reath LLP

Supreme Court Considers IRS’s Micro-Captive Reporting Requirements

On December 1, 2020, the United States Supreme Court heard oral arguments in CIC Servs. LLC v. Internal Revenue Service, a case challenging the Internal Revenue Service’s (IRS) reporting requirements around certain...more

McDermott Will & Emery

Weekly IRS Roundup August 26 – 30, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 26 – 30, 2019. August 26, 2019: The IRS released a Treasury Decision in which it issued...more

Benesch

Captive Insurance Companies for the Transportation Industry: A Quick Q&A with Those in the Know

Benesch on

Captive insurance companies are an elusive risk management strategy that, for many, is so poorly understood it is difficult to even begin consideration. Those who happen to fall into discussions of captives often bounce...more

Eversheds Sutherland (US) LLP

IRS issues simplified procedures for insurance companies to change methods of accounting to comply with amended Section 846

The Internal Revenue Service (IRS) recently released two revenue procedures that relate to the implementation of accounting method changes as a result of the revisions to Section 846 of the Internal Revenue Code of 1986, as...more

Eversheds Sutherland (US) LLP

Long-awaited passive foreign investment company proposed regulations – focus on insurance

On July 11, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued comprehensive proposed regulations on passive foreign investment companies (PFICs) that include guidance on the...more

Eversheds Sutherland (US) LLP

IRS issues key audit directive for life insurers

The Internal Revenue Service (IRS) Large Business and International (LB&I) division recently released an Industry Director’s Directive (IDD) that provides key guidance for life insurers. The IDD is the product of a two-year...more

Carlton Fields

U.S. Tax Court Finds Captive Insurer Is Not an “Insurance Company” Under the Internal Revenue Code

Carlton Fields on

In this case, Reserve Mechanical Corp. (“Reserve”), a captive insurer incorporated under the laws of Anguilla, sued the Commissioner of Internal Revenue in the U.S. Tax Court regarding the Commissioner’s findings of $477,261...more

Morgan Lewis

IRS Provides Guidance on Tax Treatment of Insurance Products

Morgan Lewis on

In a recently released memorandum, the Internal Revenue Service suggests an expansion of those risks qualifying for the favorable tax treatment accorded insurance risks....more

Blank Rome LLP

IRS Focuses Its Audit Priorities on Captive Insurance

Blank Rome LLP on

The terms "captive insurance" and "federal income tax code" are anything but captivating. Yet, captive insurance has captivated the attention of the Internal Revenue Service ("IRS"), which has placed captive insurance on its...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

Downs Rachlin Martin PLLC

Captive Insurance Update | Issue No. 1 | 2017 - A summary of state and federal developments in the captive insurance industry

Changes at the Top - Republican Phil Scott was elected Governor of Vermont in November 2016, having previously served as Lieutenant Governor for six years. Governor Scott has re-appointed Michael Pieciak to serve as the...more

Carlton Fields

IRS Treats Captives With Section 831(B) Elections As “Transactions Of Interest”

Carlton Fields on

On the heels of Congress’ amendments last year to Section 831(b) of the Internal Revenue Code to curb perceived abusive use of so-called “micro” captive insurance companies, the IRS recently issued Notice 2016-66 officially...more

Troutman Pepper Locke

Captive Insurance Arrangements Taking Advantage of Section 831(b) Election May Be Required to Report to the IRS

Troutman Pepper Locke on

The Internal Revenue Service on November 1, 2016 issued Notice 2016-66 (the Notice) requiring information reporting with respect to certain insurance or reinsurance transactions (often referred to as micro-captive...more

Eversheds Sutherland (US) LLP

IRS Provides Guidance on Reasonable Mortality Charges for Life Insurance Contracts Based on 2017 CSO Tables

On October 19, the Internal Revenue Service (IRS) issued an advance version of Notice 2016-63, addressing the “reasonable mortality charge” requirement under IRC §§ 7702 and 7702A for life insurance contracts based on the...more

Morgan Lewis

IRS Offers Tax Guidance Relating to Money Market Fund Rules

Morgan Lewis on

The IRS recently provided relief from the RIC distribution requirement for money market funds that receive contributions in connection with the transition to a floating NAV, enabling RICs to top up their NAVs without having...more

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