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Reinsurance Internal Revenue Service Insurance Industry

Downs Rachlin Martin PLLC

Captive Insurance Update | Issue 2 | 2025

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

Downs Rachlin Martin PLLC

Captive Insurance Update | Spring Edition | 2024

On March 27, 2024 the Vermont Captive Insurance Association (VCIA) held its biannual “Roadshow” educational event designed for prospective captive insurance companies. The Roadshow, which has been hosted in over 20 cities,...more

Eversheds Sutherland (US) LLP

Charting a course: Guidance issued to help navigate potential issues for insurance industry with the corporate alternative minimum...

On February 17, 2023, the Department of Treasury (Treasury) and the Internal Revenue Service (the IRS) issued Notice 2023-20 (the Notice), to provide guidance that is intended to help avoid unintended adverse consequences to...more

Downs Rachlin Martin PLLC

Captive Insurance Update | Fall Edition 2021

Developments in Vermont Federal Issues State Issues Continued Impact of COVID-19 - The measures taken by the Vermont Department of Financial Regulation (the “DFR”) in 2020 in response to the COVID-19 pandemic have been...more

Troutman Pepper Locke

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

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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

Downs Rachlin Martin PLLC

2016 Captive Insurance Update | Issue 2 | 2016

Governor Peter Shumlin (D-Vt.) is not running for re-election this fall, so Vermont will have a new governor in January 2017. In addition, the Commissioner of the Vermont Department of Financial Regulation (DFR), Susan...more

Carlton Fields

IRS Revokes Ruling That Imposed Excise Tax On Wholly Foreign Reinsurance Transactions

Carlton Fields on

The Internal Revenue Service recently revoked a 2008 ruling that a 1% excise tax under section 4371(3) of the Internal Revenue Code applied to “reinsurance premiums paid by one foreign insurer or reinsurer to another.” The...more

Troutman Pepper Locke

Insurance Newsletter September 2015

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On May 26, 2015, the United States Court of Appeals for the District of Columbia upheld a District Court decision and ruled that the Internal Revenue Service could not impose excise tax on certain wholly-foreign retrocessions...more

Troutman Pepper Locke

Validus Round Two: Court of Appeals’ Decision Holding That Wholly-Foreign Retrocessions Are Not Subject to Federal Excise Tax...

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On May 26, 2015, the United States Court of Appeals for the District of Columbia upheld a District Court decision and ruled that the Internal Revenue Service could not impose excise tax on certain wholly-foreign retrocessions...more

Carlton Fields

D.C. Circuit Holds That Wholly Foreign Retrocessions Not Subject To U.S. Excise Tax

Carlton Fields on

In late May, the United States Court of Appeals for the District of Columbia Circuit affirmed a grant of summary judgment to a reinsurer in a dispute with the IRS regarding the imposition of U.S. excise taxes on a wholly...more

Carlton Fields

IRS Proposes Regulations Directed To “Passive” Hedge Fund Foreign Insurance Entities

Carlton Fields on

On April 24, 2015, the Internal Revenue Service proposed regulations directed to “situations in which a hedge fund establishes a purported foreign reinsurance company in order to defer and reduce the tax that otherwise would...more

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