Chris Flanagan, Partner at Locke Lord LLP, and Jim Sabella, CPA and Tax Partner at Dixon Hughes Goodman LLP, will present a webinar on Tax Reform: Implications for Insurers and Reinsurers. This webinar is sponsored by CCIA Delta and hosted by 202works, and will provide key insights into the
Christopher Flanagan
You’re Invited – Insurance M&A and Capital Raising Roundtable
Please join BDO USA, LLP, Locke Lord LLP, and Sandler O’Neill + Partners, L.P. for a complimentary breakfast briefing. This event will highlight key considerations in a successful M&A transaction or capital raising transaction in today’s economic climate for the insurance industry.
A panel discussion will follow discussing tax reform…
New Tax Law May Reduce Tax Benefit for Cross-Border Affiliated Insurance/Reinsurance Premiums
On December 22, 2017, the President signed into law H.R. 1, known generally as the Tax Cuts and Jobs Act (the “TCJA”), which makes widespread changes to the Internal Revenue Code. The TCJA includes a number of provisions that impact the taxation of the insurance and reinsurance sector, particularly in…
Disclosure Deadlines Extended for Participants in and Material Advisors to Micro-Captive Transactions
On December 29, 2016, the Internal Revenue Service issued Notice 2017-08, extending the disclosure deadlines for participants in and material advisors to certain micro-captive transactions.
Prior guidance from the Service, issued in Notice 2016-66, had identified certain micro-captive transactions as “transactions of interest” and indicated that the general disclosure requirements…
Captive Insurance Arrangements Taking Advantage of Section 831(b) Election May Be Required to Report to the IRS
Posted in Captives, United States
The Internal Revenue Service on November 1 issued Notice 2016-66, which requires information reporting with respect to certain insurance or reinsurance transactions involving captive insurance companies that claim the benefits of an election under Section 831(b) of the Internal Revenue Code available to certain small insurance companies, often referred to…
Rhode Island Proposes Innovative Approach to Reduce Premium Tax Rate
By Christopher Flanagan on
Posted in Tax Related Developments
Parallel bills proposing to reduce the current two-percent Rhode Island insurance premium tax are before both the Rhode Island House and Senate. Working with the Rhode Island Department of Business Regulation, Representative Joseph Shekarchi (who is the primary author of the House bill) and Senator William Walaska (who is…
New York State Clarifies Taxation of Unauthorized Insurance Companies
Posted in New York Developments, Tax Related Developments
Three recent decisions (March 3, 2016) by a New York State Division of Tax Appeals administrative law judge help to clarify the taxation of unauthorized insurance companies subject to New York State taxation.
New York State has over recent years changed in certain significant regards both the substantive law and…
Congress Expands and Tightens Section 831(b) Small Insurance Company Election
On December 18, 2015, Congress enacted the Protecting Americans from Tax Hikes Act of 2015, making, among other items, several significant changes to the provisions of Internal Revenue Code Section 831(b), which provides generally favorable tax treatment for electing small insurance companies. Certain of these changes…
Ninth Circuit Overturns Taxpayer-Friendly Decision in Demutualizations
On December 9, in Dorrance v. The United States, the Ninth Circuit overturned a favorable district court decision for taxpayers in demutualizations. The Ninth Circuit ruled that a taxpayer owning insurance policies in a mutual insurance company had a zero tax basis in the attendant membership rights which accompanied…
Legislation Reintroduced to Clarify Application of NRRA to Captives
As discussed in our earlier article on the topic (a copy of which can be accessed here) and our prior entry on this site (which can be accessed here), uncertainty remains over whether the self-procurement tax and regulatory provisions of the Non-admitted and Reinsurance Reform Act, enacted as a part…