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Higgs & Johnson Counsel & Attorneys at Law | Bahamas, Global | 9 Dec 2019

A Thought on Captives

Captive insurance is often, and rather myopically, perceived of as the preserve of multinational conglomerates whose risks may be too complex or too…
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Morrison & Foerster LLP | USA | 4 Jun 2019

Third department upholds decision denying deductibility of payments made to Captive Insurance company

In Matter of Stewart's Shops Corp., No. 525841, 2019 NY Slip Op. 04062, (3d Dep't, May. 23, 2019), the Appellate Division, Third Department, affirmed…
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Ford & Harrison LLP | USA | 11 Dec 2018

Home Care Agencies Sued for Illegal Use of Captive Insurance Company

Class action attorneys recently filed a first-of-its-kind class action against Edison Home Health Care (“Edison”) and Preferred…
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McDermott Will & Emery | USA | 21 Nov 2018

Illinois Moves One Step Closer to Enacting Captive Reform

On November 14, the second day of its 2018 veto session, the Illinois Senate voted unanimously to override Governor Rauner’s amendatory veto of Senate…
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Clyde & Co LLP | United Kingdom | 4 Jul 2018

Update on policy proposals regarding Third-party Cell Captive Insurance and Similar Arrangements

On 3 July 2018, the Financial Sector Conduct Authority and the Prudential Authority published a joint communication which provides an update on the…
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Steptoe & Johnson LLP | OECD, USA | 3 Jul 2018

OECD Releases Discussion Draft on Transfer Pricing Aspects of Financial Transactions

Today, the OECD released its latest discussion draft on the application of transfer pricing principles to financial transactions. The first part of…
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Dentons Bingham Greenebaum LLP | USA | 10 Nov 2017

Tax Court: no insurance to be found in avrahami’s Captive Insurance arrangement

On August 21, 2017, the United States Tax Court, in Avrahami v. Commissioner, 149 T.C. No. 7 (2017), issued its opinion in the first case involving a…
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Holland & Knight LLP | USA | 6 Oct 2017

Takeaways from the Tax Court's First Micro-Captive Insurance Ruling

The U.S. Tax Court recently ruled in Avrahami v. Commissioner, the first litigated Tax Court case involving an 831(b) captive insurance…
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Bressler, Amery & Ross PC | USA | 28 Aug 2017

Guideline to Scrutiny: Avrahami Provides IRS with Roadmap to “Small Captive” Oversight

In the past two years, the IRS has continued its oversight of the use and tax implications of captive insurance companies which make a “small…
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Eversheds Sutherland (US) LLP | USA | 3 Aug 2017

New York State Tax Appeals Tribunal: Payments to Captive Insurance Company Did Not Qualify as Deductible Insurance Premiums

The New York State Tax Appeals Tribunal released its precedential decision in Stewart’s Shops, affirming an Administrative Law Judge’s determination…
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