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The trials and tribulations of 831(b)s
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
Reserve Mechanical and the war on small captives
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
Accounting & tax analysis
Tax reform is generally positive for US-domiciled captives and a mixed bag for offshore captives, however it has not affected any credit ratings, according to an AM Best briefing.   19 June 2018
Accounting & tax analysis
The US economy is performing well and remains on a positive trajectory – but there are concerns over it overheating and the medium-term implications of the deficit, two notable economists agreed at a panel discussion held on Wednesday morning at the annual Bermuda Captive Conference, which is taking place at the Fairmont Southampton Hotel on Bermuda this week.   13 June 2018
Accounting & tax analysis
The State of Vermont has passed new legislation offering an onshore affiliated reinsurance alternative to insurers affected by the recent imposition of the Base Erosion Anti-Abuse Tax (BEAT) on reinsurance ceded to offshore affiliates.   17 May 2018
Accounting & tax analysis
The UK House of Commons has passed a bill that would require public ownership registers in the Cayman Islands and other British Overseas Territories by December 2020.   3 May 2018

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