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.
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.
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.
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.
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.
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.
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.
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.
The Internal Revenue Service (IRS) has concluded its annual "Dirty Dozen" list of tax scams for 2018, placing "abusive" microcaptives on there for the fourth consecutive year.
The US Tax Cuts and Jobs Act 2017 represents the first major overhaul to federal taxes since 1986, and there are provisions that both US and international captives must be wary of. But changes are not expected to impact the numbers of captives formed.