Tax Planning, Insurance Industry, Tax Reform

The Standard Formula: Encyclopaedia of Prudential Solvency – Chapter 2: The Bermuda Prudential Solvency Regime

Skadden, Arps, Slate, Meagher & Flom LLP on 3/17/2025

This chapter discusses the Bermudian prudential solvency regime. Bermuda rose to prominence in the insurance and reinsurance industries in the late 1960s and early 1970s, largely due to its pioneering work in the...more

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

Gerald Nowotny - Law Office of Gerald R.... on 3/7/2025

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

Las Mañanitas

Gerald Nowotny - Law Office of Gerald R.... on 1/28/2025

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

The Inside Basis: Tax Insurance in Luxembourg

K&L Gates LLP on 1/13/2025

In our second episode of The Inside Basis, Randy Clark is joined by Marion Zeller, a tax partner in our Luxembourg office, and David Mussche, an associate director with Howden M&A's tax team, to discuss the state of tax...more

Another Attack on Private Placement Life Insurance

Levenfeld Pearlstein, LLC on 1/9/2025

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

New Tax Law Eliminates 30-Day Safe Harbor Against CFC Status

Carlton Fields on 4/10/2018

The recent tax law changes have focused primarily on corporate income tax, and in the international context, mostly on outbound tax matters. However, certain less publicized changes to the Code’s controlled foreign...more