Home News August "CICR" Analyzes IRS CCA on Micro-Captive Withholding Tax

August "CICR" Analyzes IRS CCA on Micro-Captive Withholding Tax

Abstract Clear Globe and Reflection Against Blue Background Surrounded by Swirls

August 05, 2024 |

Abstract Clear Globe and Reflection Against Blue Background Surrounded by Swirls

Don't miss the August issue of Captive Insurance Company Reports (CICR), which breaks down an Internal Revenue Service (IRS) Chief Counsel Advice (CCA) addressing the treatment of non–US-domiciled micro-captives when transactions are not considered insurance, focusing on withholding tax applicability under § 881(a). Find out about the need for rules to determine payment sources and consequences when non-US entities engaged in US trade or business fail to file timely returns.

In the Newest Issue of CICR

  • Discover current observations suggesting that tribal sovereignty is being leveraged in the captive insurance industry to bypass state regulations, and resulting concerns about regulatory compliance, ethical practices, and the oversight of rapidly growing captive reinsurers within some tribal domiciles.
  • Get insights on employing parametric risk transfer (PRT) at the 2024 Summer Olympics in Paris. PRT utilizes predefined triggers to ensure quick and transparent payouts.
  • Learn about the first modern-era captive syndicate at Lloyd's of London, which was launched by Apollo Syndicate Management.
  • Meet Abi Potter Clough, who provides for her first edition as the new CICR editor an overview of recent industry reports highlighting the growth of the captive insurance market amid challenging conditions.

If you subscribe to CICR in Vertafore ReferenceConnect or IRMI Online, you can access the August issue at the links below.

Vertafore ReferenceConnect Subscribers

IRMI Online Subscribers

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August 05, 2024