Selected tax issues in alternative risk management and for captives
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Tax Issues Generally
Discussion of tax issues relating to captives and other alternative risk transfer and management issues other than those listed in one of the forums below.
- 4 Topics
- 4 Posts
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Last post by Jay
Sun Dec 14, 2008 10:07 am
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Federal Risk Shifting and Insurance Contracts
Discussion of the federal tax law requirements for "insurance" as they relate to the shifting of risks and what constitutes a valid insurance contract as opposed to an economic hedge.
- 1 Topics
- 1 Posts
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Last post by Jay
Tue Nov 25, 2008 5:46 pm
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Federal Risk Distribution
Discussion of the federal tax law requirements of risk distribution, including what does and does not qualify for the 12+ affiliate safe harbor, and attribution issues.
- 6 Topics
- 8 Posts
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Last post by frieda
Thu Jul 29, 2010 10:56 am
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Federal Excise Taxes on Insurance
Discussion of the federal excise taxes on insurance premiums paid, including premiums paid to offshore captive insurance companies
- 1 Topics
- 0 Posts
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Last post by Jay
Sun Dec 14, 2008 10:18 am
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831(b) Election
Discussion of the 831(b) election for insurance companies whose annual net premium income does not exceed $1.2 million per year.
- 2 Topics
- 2 Posts
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Last post by Jay
Thu Nov 27, 2008 8:36 am
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501(c)(15) Exempt Insurance Companies
Discussion of insurance companies qualifying for exempt treatment under IRC section 501(c)(15) for gross receipts not exceeding $600,000 per year of which at least half those receipts are premium income.
- 8 Topics
- 8 Posts
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Last post by Jay
Tue Dec 16, 2008 11:36 am
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State Income Tax and Independently Procured Tax Issues
Discussion of state income tax issues for alternative risk management transactions and captives, including whether out-of-state captives are subject to state income tax and whether a state may assess a premium tax or independently procured tax to premiums paid to captives.
- 2 Topics
- 2 Posts
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Last post by Jay
Sun Mar 22, 2009 9:30 am
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Foreign Captives and Tax Treaties
Discussion of the unique reporting requirements for U.S.-owned foreign captives, and the tax treaties between the United States and foreign countries as such treaties may impact captive insurance arrangements. Includes discussion of the 953(d) election.
- 6 Topics
- 6 Posts
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Last post by Jay
Sun Dec 14, 2008 10:18 am
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Tax Reporting and Audits
Discussion of the tax reporting of U.S.-owned captive insurance companies, both domestic and foreign, and audit procedures and experiences.
- 3 Topics
- 2 Posts
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Last post by Jay
Sun Dec 14, 2008 8:54 am
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- IRS on Foreign Insurance Excise Tax
by Jay » Sun Dec 14, 2008 10:18 am
- 0 Replies
- 1084 Views
- Last post by Jay
Sun Dec 14, 2008 10:18 am
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- IRS on Captives Generally
by Jay » Sun Dec 14, 2008 10:07 am
- 0 Replies
- 944 Views
- Last post by Jay
Sun Dec 14, 2008 10:07 am
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- IRS on Cascading and Captive Insurance and Reinsurance
by Jay » Sun Dec 14, 2008 9:59 am
- 0 Replies
- 164 Views
- Last post by Jay
Sun Dec 14, 2008 9:59 am
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- IRS on Consolidated Returns
by Jay » Sun Dec 14, 2008 8:54 am
- 0 Replies
- 561 Views
- Last post by Jay
Sun Dec 14, 2008 8:54 am
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- IRS on Reinsurance - Foreign
by Jay » Sun Dec 14, 2008 8:42 am
- 0 Replies
- 343 Views
- Last post by Jay
Sun Dec 14, 2008 8:42 am
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- IRS on Foreign Insurance Tax Claims
by Jay » Sun Dec 14, 2008 8:30 am
- 0 Replies
- 369 Views
- Last post by Jay
Sun Dec 14, 2008 8:30 am
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- IRS on Section 953(d) Election
by Jay » Sun Dec 14, 2008 8:26 am
- 0 Replies
- 288 Views
- Last post by Jay
Sun Dec 14, 2008 8:26 am
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- IRS on Closing Agreements and Income Tax Returns - Foreign
by Jay » Sun Dec 14, 2008 8:22 am
- 0 Replies
- 255 Views
- Last post by Jay
Sun Dec 14, 2008 8:22 am
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- IRS Treaty Country Listing as of April 2008
by Jay » Sun Dec 14, 2008 8:14 am
- 0 Replies
- 176 Views
- Last post by Jay
Sun Dec 14, 2008 8:14 am
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- Notice 2003-34 Offshore Entities Investing in Hedge Funds
by Jay » Thu Nov 27, 2008 8:56 am
- 0 Replies
- 329 Views
- Last post by Jay
Thu Nov 27, 2008 8:56 am
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- Revenue Ruling 2008-8 on Protected Cell Captives
by Jay » Thu Nov 27, 2008 8:51 am
- 0 Replies
- 3204 Views
- Last post by Jay
Thu Nov 27, 2008 8:51 am
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- Comment on Effective Abolition of 501(c)(15)
by Jay » Thu Nov 27, 2008 8:27 am
- 0 Replies
- 248 Views
- Last post by Jay
Thu Nov 27, 2008 8:27 am
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- Anecdotal Evidence of IRS Withdrawing Exemptions
by Jay » Tue Dec 16, 2008 11:36 am
- 0 Replies
- 589 Views
- Last post by Jay
Tue Dec 16, 2008 11:36 am
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- IRS on Pooling of Risks
by Jay » Sun Dec 14, 2008 8:51 am
- 0 Replies
- 718 Views
- Last post by Jay
Sun Dec 14, 2008 8:51 am
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