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Requests comments on a revenue ruling concerning taxation of protected cell captive arrangements

Edwards Wildman Palmer LLP
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USA
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February 25 2008

In a recently released revenue ruling, the IRS has established procedures for determining if insurance written through protected cell companies constitutes insurance for federal income tax purposes

Proposed captive tax deduction rule withdrawn by IRS

Edwards Wildman Palmer LLP
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USA
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February 27 2008

The Internal Revenue Service announced on February 20, 2008 that it is withdrawing the proposed IRS Regulation 1.1502-13(e)(2)(ii)(C

IRS launches voluntary compliance FET initiative for certain foreign insurers

Edwards Wildman Palmer LLP
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USA
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March 14 2008

On March 7, 2008 the Internal Revenue Service (“IRS”) issued Revenue Ruling 2008-15 which clarifies the U.S. tax consequences when a foreign insurer enters into a reinsurance agreement with another foreign insurer

U.S. insurers urge Congress to modify provisions of current tax law related to foreign insurers

Edwards Wildman Palmer LLP
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USA
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October 31 2007

On September 26, 2007, William R. Berkley, Chairman and C.E.O. of W.R. Berkley Corporation, the ninth largest commercial insurer in the U.S., addressed the Senate Finance Committee concerning an alleged flaw in the current U.S. tax system that provides certain economic advantages to foreign property and casualty insurers domiciled in favorable tax jurisdictions, such as Bermuda

IRS reaffirms position regarding “cascading”: application of Federal Excise Tax

Edwards Wildman Palmer LLP
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USA
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June 16 2008

On March 7, 2008, the US Internal Revenue Service (the IRS) issued Revenue Ruling 2008-15 reaffirming its long-held position that the Federal Excise Tax on insurance and reinsurance premiums (the FET) imposed by Sections 4371 et seq. of the US Internal Revenue Code of 1986, as amended (the Code) applies to reinsurance contracts between foreign insurance companies

IRS issues guidance relating to tax consequences of life insurance transactions

Edwards Wildman Palmer LLP
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USA
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May 12 2009

On May 1, 2009, the Internal Revenue Service ("IRS") issued Revenue Rulings 2009-13 and 2009-14 with respect to the federal income tax treatment of certain life insurance transactions, including life settlements

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

New Jersey increases surplus lines premium tax rates

Edwards Wildman Palmer LLP
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USA
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July 8 2009

The New Jersey Department of Banking and Insurance recently issued Bulletin 09-21, which advises that amendments to N.J.S.A. 17:22-6.59 and 17:22-6.64 were enacted on June 29, 2009

White House seeks additional tax revenue from the life insurance industry

Edwards Wildman Palmer LLP
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USA
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July 9 2009

In its recently released General Explanation of the Administration’s Fiscal Year 2010 Revenue Proposals (the "Green Book"), the United States Department of the Treasury detailed the White House’s tax revenue proposals

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

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