Taxation
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. Learn 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. Learn 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
White Paper Explores Key Concepts in Insurance and Reinsurance for Captives
This white paper provides an in-depth look at essential insurance and reinsurance concepts, including risk pooling, exposure units, and the circular flow of funds. Authored by industry experts including Alan Fine from Armanino, it offers practical insights for professionals navigating the complexities of commercial and captive insurance. Read More
Captive Insurance under Fire: Recent Court Cases and IRS Regulations Reshape the Industry
Recent court cases and Internal Revenue Service (IRS) regulations are increasing scrutiny on micro-captives, prompting the captive insurance industry to navigate evolving legal and regulatory challenges. Read More
Micro-Captive IRS Audit Guidance Indicates Withholding Tax To Be Imposed
Internal Revenue Service (IRS) audit guidance indicates withholding tax on micro-captive premiums, following the "Reserve Mechanical" ruling, which voided tax exemptions under IRC section 953(d) and 501(c)(15). Read More