Articles
Accounting & tax analysis
A hardening market has prompted many companies to explore ways of leveraging their captive to help dodge or at least offset some of the rate increases, according to Jason Flaxbeard, executive managing director, captive management and consulting, Beecher Carlson. 12 June 2019
Accounting & tax analysis
Captive premium growth for cyber risk has accelerated by 263 percent in the past year, according to Aon. 11 June 2019
Accounting & tax analysis
Just 10 days before the scheduled trial in the US Tax Court, the taxpayers conceded the remaining issues in Pilot Series of Fortress Insurance et al v Commissioner. The pretrial pleadings highlighted many of the key questions that remain open in litigation over the tax treatment of captive insurance transactions. Those questions—and the parties’ efforts to answer them—provide a roadmap of what to expect as additional cases move toward trial. Jenny Johnson Ware, founding partner of tax litigation boutique Johnson Moore, analyses those key questions and what we can learn from them—despite the fact that the Tax Court will not be providing any answers. 7 June 2019
Accounting & tax analysis
The Internal Revenue Service (IRS) had planned to use tape recordings of an undercover agent looking to form an 831(b) captive with Tribeca Strategic Advisors - now part of Artex Risk Solutions - in order to support its argument that a captive in a recent lawsuit lacked economic substance. 3 June 2019
Accounting & tax analysis
The failure of a captive can often be traced to a breakdown in quality corporate governance. Ben Whitehouse, senior counsel at Butler Snow, outlines the important attributes of good captive governance. 31 May 2019
Accounting & tax analysis
Could high-profile settlements with the State of Washington lead to more captive domiciles following a similar path? Or will they adopt a more pro-business stance, like North Carolina? Pete Kranz, executive managing director and captive practice leader of Beecher Carlson, provides some key considerations on where to domicile a captive. 15 May 2019
Accounting & tax analysis
The Internal Revenue Service (IRS) has launched a compliance campaign to ensure US multinational companies are paying their captive service providers no more than arm's length prices. 23 April 2019
Accounting & tax analysis
The outcome of Syzygy v Commissioner marks another IRS victory against 831(b) captives. What went wrong this time? Matthew Queen, general counsel & chief compliance officer, Venture Captive Management, has the details. 15 April 2019
Accounting & tax analysis
Just like Reserve Mechanical and Avrahami before it, the US Tax Court has ruled in favour of the IRS in the case of Syzygy Insurance v Commissioner, ultimately determining the captive did not constitute insurance in the commonly accepted sense and its 831(b) election was invalid. 11 April 2019
Accounting & tax analysis
Leadville Insurance Company, the Vermont-based captive insurance subsidiary of US department store chain Macy’s, may be liable for $23.8 million in unpaid corporate income taxes to the state of Maryland, a recent court opinion has shown. 29 March 2019
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