Topic: Tax Related Developments

Ninth Circuit Overturns Taxpayer-Friendly Decision in Demutualizations

The Ninth Circuit has overturned a favorable decision for taxpayers in demutualizations, ruling that taxpayers have a zero basis in their membership interests in the former mutual insurance company, and therefore also in the shares of stock received in a demutualization of the company. As a result, all proceeds from a subsequent sale of such shares is taxable as gain.

Read More

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 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, apply to non-admitted insurance procured from a captive insurance company.

Read More




Email the Editor

Click here to Email the Editor

Locke Lord LLP

For the latest information about our Firm visit