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Tax treatment of carried interest could be revived in Senate

Edwards Wildman Palmer LLP
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USA
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April 16 2010

Though the Senate passed its Tax Extenders legislation in mid-March without including House language to change the tax treatment of the "carried interest" income of investment managers, the issue may receive a second look in the coming weeks

Health care legislation imposes tax on annuity income

Edwards Wildman Palmer LLP
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USA
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April 26 2010

The Health Care and Reconciliation Act (the "Act"), signed into law on March 30, 2010, imposes a tax on annuity income to help pay for the multi-billion dollar reform package set forth in both the Act and the Patient Protection and Affordable Care Act, signed into law on March 23, 2010

Rhode Island 2011 budget - tax implications for surplus lines insurers and medical malpractice joint underwriters association

Edwards Wildman Palmer LLP
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USA
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June 16 2010

The 2011 Rhode Island state budget, which was enacted as HB 7397A and signed into law June 2, 2010, amends the taxation statutes applicable to surplus lines insurers and the Medical Malpractice Joint Underwriters Association

Obama proposes budget that would end foreign reinsurer tax advantages

Edwards Wildman Palmer LLP
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USA
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February 3 2010

President Barack Obama’s recently released proposed Budget of the U.S. Government for the Fiscal Year 2011 (the “Proposed 2011 Budget”) would disallow the deduction for excess non-taxed reinsurance premiums paid to foreign affiliates by a U.S. insurance company

Ambac and IRS come to temporary terms regarding dispute over $700 million in tax refunds

Edwards Wildman Palmer LLP
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USA
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November 29 2010

As previously discussed here, Ambac Financial Group Inc. has filed for bankruptcy for Chapter 11 bankruptcy relief with United States Bankruptcy Court for the Southern District of New York

2011 revenue proposals have implications for life settlements

Edwards Wildman Palmer LLP
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USA
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February 11 2010

Earlier this month, the Obama Administration released its 2011 Budget and accompanying revenue proposals (“Revenue Proposals”) which set forth the means by which the U.S. Government proposes to pay for the items set forth in the 2011 Budget

New York Insurance Department considering requesting lower federal tax rate

Edwards Wildman Palmer LLP
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USA
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March 8 2010

According to media reports, New York Insurance Department (the “Department”) Superintendent James Wrynn announced at a membership meeting of the Association of Insurance & Reinsurance Run-Off Companies (AIRROC) that the Department’s tax working group is reviewing whether a revived New York Insurance Exchange (the “Exchange”) should request a lower federal corporate tax rate

German government opposes US legislation limiting deductibility of reinsurance premiums

Edwards Wildman Palmer LLP
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Germany, USA
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July 28 2010

Proposed legislation that would limit a tax deduction for reinsurance premiums paid to a foreign affiliate of a US insurer has drawn the formal opposition of the German government

In private letter ruling, IRS says captive reinsurance of fronted pools is “insurance” for tax purposes

Edwards Wildman Palmer LLP
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USA
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January 4 2010

The Internal Revenue Service (IRS) issued a private letter ruling on December 11, 2009, resolving a taxpayer’s question as to whether its business as a captive reinsurer is "insurance" for tax purposes

California appeals court affirms ruling that Section 28 tax does not apply to surplus lines insurers

Edwards Wildman Palmer LLP
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USA
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October 7 2010

On September 30, 2010, the California Court of Appeal for the Second Appellate District affirmed a superior court ruling that California Constitution Section 28 taxes do not apply to surplus lines insurers