Taxation
Breaking Down the IRS's Final Regulations on Micro-Captive Insurance Transactions
The Internal Revenue Service (IRS) finalized regulations on micro-captive insurance, revising criteria for listed transactions and transactions of interest. New disclosure rules affect 831(b) captives, with a 90-day compliance window. Exemptions apply for consumer coverage reinsurance, and a new process allows streamlined revocation of the 831(b) election under Rev. Proc. 2025–3. Learn More
IRS Finalizes Micro-Captive Regulations
The Internal Revenue Service (IRS) and the Treasury Department issued final regulations on micro-captive insurance arrangements, marking an effort to refine the framework for identifying and reporting abusive practices. Learn More
Ryan LLC Challenges IRS Micro-Captive Insurance Rule in Federal Court
Ryan LLC has filed suit against the Internal Revenue Service (IRS), contesting a rule on micro-captive insurance transactions. The firm claims the regulation exceeds authority, disrupts small business risk management, and imposes arbitrary loss ratio thresholds. Read More
Navigating Bermuda's New Corporate Income Tax: Insights from Bermuda Captive Conference
This article examines Bermuda's corporate income tax for multinational enterprises, focusing on compliance obligations, economic transition adjustments, and financial impacts. Insights from the Bermuda Captive Conference reveal how the tax aligns with global standards, enhancing transparency and operational predictability for affected entities. Read More
Tax Court Examines Tribal-Domiciled Captive Insurer in Recent Case
The US Tax Court ruled in favor of the Internal Revenue Service in a case involving a tribal-domiciled captive insurer. The lack of structured insurance regulation in the Sac and Fox Nation was a notable factor in the court's decision, highlighting the importance of regulatory oversight in selecting a domicile. Read More
Bermuda Expected To Maintain Market Stability Amid 15 Percent Corporate Tax
Bermuda's new 15 percent corporate tax, effective in 2025, is unlikely to deter its insurance and reinsurance market. The island's established regulatory regime and industry expertise continue to be key attractions for multinational insurers, outweighing concerns about the new tax rate. Read More
Royal Management: Another 831(b) Tax Court Decision
The Tax Court's decision in Royal Management v. Commissioner examines an 831(b) insurance arrangement, identifying key issues such as risk shifting, risk distribution, and policy timing. The court found these elements insufficient for the arrangement to qualify as valid insurance for tax purposes, providing insights into the complexities of such cases. Read More