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Accounting & tax analysis
Clients that have parent companies with headquarters or operating units in Washington state should consult their tax professionals following the settlement of the case involving Microsoft’s Arizona-based captive being issued a cease & desist letter, warns JLT Insurance Management (JLT IM). 20 August 2018
Accounting & tax analysis
If the IRS continues to gain victories against small captives in the US Tax Court, it may be emboldened to target larger captives, according to Charles “Chaz” Lavelle, partner at Bingham Greenebaum Doll, speaking to Captive International at the VCIA annual conference. 8 August 2018
Accounting & tax analysis
Tax reform is affecting every corporation in the US and the captive industry is no different. The Base Erosion Anti-Abuse Tax (BEAT) provisions in particular may drive captives to redomicile onshore. 8 August 2018
Accounting & tax analysis
Upcoming US Tax Court cases - Caylor, Wilson, and Syzygy Insurance - have likely been selected by the IRS to target deficient captive models; but the outcomes of these cases should not hurt growth in the legitimate captive market. 8 August 2018
Accounting & tax analysis
Against a backdrop of legal battles and regulatory changes, small captives have been through a lot. But how much has the landscape changed, and are 831(b)s still an attractive option for the middle market? US Captive investigates. 6 August 2018
Accounting & tax analysis
Following the outcomes of Avrahami and more recently Reserve Mechanical, upcoming US Tax Court cases - Caylor v Commissioner, Wilson v Commissioner and Syzygy Insurance v Commissioner - are likely to suffer similar fates, spelling further IRS victories. 6 August 2018
Accounting & tax analysis
Much like Avrahami, the Reserve Mechanical case is another notch on the IRS’s belt as it continues on its warpath against small captives, hurting the legitimate structures in the process. But what went wrong? Matthew Queen of Venture Captive Management breaks it down. 9 July 2018
Accounting & tax analysis
Capstone Associated Services, the operator of Reserve Mechanical's risk pool entity Pool Re Insurance, has issued a second statement on the US Tax Court case following the opinion issued by Judge Kathleen Kerrigan. 28 June 2018
Accounting & tax analysis
As the dust settles on the US Tax Court's latest ruling against a small captive, the captive insurance industry is still examining what the Reserve Mechanical Corp v Commissioner case means for the sector. 26 June 2018
Accounting & tax analysis
In a decision that may place captive insurance companies under further scrutiny, the US Tax Court has ruled in favour of the IRS in the case of Reserve Mechanical Corp v Commissioner. 19 June 2018
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