Taxation
Minnesota Includes Captives in Direct Procurement Tax Form Changes
The Minnesota Department of Revenue is taking comments on proposed changes that, among other things, would specify that the state's nonadmitted premium tax for direct procured insurance applies to captive insurance. The proposal would modify Form IG255, the state's nonadmitted insurance premium tax return form, to specifically mention captives. Read More
SIIA Seeks Treasury Department Review of IRS 831(b) Captive Activities
In a letter to US Treasury Secretary Steven Mnuchin and Russel Vought, acting director of the Office of Management and Budget, the Self-Insurance Institute of America (SIIA) has asked the Treasury Department to review activities of the Internal Revenue Service (IRS) related to 831(b) captive insurance companies. Read More
North Carolina Captive Group Seeks Relief from IRS Micro-Captive Letter
The North Carolina Captive Insurance Association (NCCIA) is one of a number of state captive insurance associations protesting recent Internal Revenue Service (IRS) activities aimed at micro-captives. The NCCIA wrote North Carolina's congressional delegation for help in securing relief from a letter the IRS sent in March to micro-captive owners. Read More
Quiet Settlement in 831(b) Captive Insurance Tax Case
Wilson v. Comm'r, Docket 26547-13 (Tax Court) was quietly settled at the end of February. The case had been in the Tax Court for some time, and after Avrahami was decided, supplemental briefs were requested by the court. The facts of the case are very similar to Avrahami. Read More
Captive Insurance Groups File Brief Supporting Reserve Tax Case Appeal
A group of captive insurance associations filed a friend of the court brief supporting Reserve Mechanical Corp.'s appeal of a US Tax Court insurance tax case. The group expressed concern about areas of the Tax Court's ruling concerning prior loss history, standardized versus manuscripted policies, and risk pooling. Read More