Taxation
Reserve Files Opening Appeals Brief in Captive Insurance Tax Case
Reserve Mechanical Corp.'s first appeals brief outlines ways it says the US Tax Court erred in ruling against it in a captive insurance tax case, arguing that the captive insurance arrangement met necessary criteria for insurance. Read More
Cayman Islands Added to the EU "Blacklist"
The Council of the European Union recently revised its so-called blacklist of noncooperative tax jurisdictions to include Cayman Islands. Read More
Johnson & Johnson Successful on Appeal of New Jersey Tax Court Decision
Johnson & Johnson was successful on appeal of a New Jersey Tax Court decision regarding independently procured tax. The court found Johnson & Johnson liable only for independent procurement tax on New Jersey risk related to premium paid to its captive insurance company. Read More
What a Captive Insurer Should Know about the Federal Excise Tax
The federal excise tax (FET) is imposed at the federal level on insurance premiums or reinsurance premiums that are paid by a US person to a foreign non-US person with regard to US risks. Bruce Wright, partner at Eversheds Sutherland (US) LLP, discusses what captive owners should know about FET. Read More
Syzygy Captive Not in the Business of Insurance, According to Tax Court
In Syzygy Ins. Co. v. Commissioner, T.C. Memo 2019-34, the Tax Court considered yet another case involving a company that had elected to be taxed under section 831(b) of the Internal Revenue Code of 1986. Read More