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IRS treats captives with Section 831(b) elections as “transactions of interest”

USA - December 12 2016 On the heels of Congress’ amendments last year to Section 831(b) of the Internal Revenue Code to curb perceived abusive use of so-called “micro”…

Department of Labor Rule Paves the Way for State-Run Retirement Plans

USA - October 13 2016 On August 24, the United States Department of Labor (DOL) announced a final rule governing the exemption of state-run retirement plans from the…

IRS revokes ruling that imposed excise tax on wholly foreign reinsurance transactions

USA - February 8 2016 The Internal Revenue Service recently revoked a 2008 ruling that a 1% excise tax under section 4371(3) of the Internal Revenue Code applied to…

The practical need for managers of micro captives and the allure of 'off label' uses

USA - September 11 2015 Every tax season, the Internal Revenue Service releases a "Dirty Dozen" list of schemes that it considers abusive and widespread enough to present a…

Whitney Fore

What the insurance industry should know about the IRS’s campaign against “abusive” micro captives

USA - June 29 2015 Though in the midst of a stifling budget and personnel reduction, the United States Internal Revenue Service (“IRS”) recently announced an increased…

Whitney Fore