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Reinsurance Tax Court

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 | 2019: A summary of state and federal developments in the captive insurance industry

There were no significant changes in Vermont’s leadership team during the last election cycle. Governor Phil Scott, a Republican, was re-elected in November 2018 for another two-year term. Michael Pieciak, the Commissioner of...more

Carlton Fields

Tax Court Rejects Captive Insurance Company Status Under 501(c)(15)

Carlton Fields on

Petitioner, a captive insurer domiciled in Anguilla, applied to be a tax-exempt small insurance company under IRC section 501(c)(15), and filed returns on this basis, making an election under IRC section 953(d)....more

Carlton Fields

Court Upholds Attorney-Client Privilege Despite Advice Of Counsel Defense In Tax Case Involving Reinsurance Transaction

Carlton Fields on

This case involves a tax dispute centering on whether certain “purported” insurance and reinsurance transactions “lacked economic substance.” Following an in camera review of communications identified in Respondents’...more

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