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Taxation Issues Relating To Captive Insurance Companies
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Book Synopsis Taxation Issues Relating to Captive Insurance Companies by : Arvid Aage Skaar
Download or read book Taxation Issues Relating to Captive Insurance Companies written by Arvid Aage Skaar and published by . This book was released on 1998 with total page 350 pages. Available in PDF, EPUB and Kindle. Book excerpt: Analysis of the tax treatment of premiums paid to captives. Case law from the US, Germany, the Netherlands, Norway and Australia are compared in order to establish the conditions under which a captive is considered to be a bona fide insurance company. The application of the generally accepted transfer pricing methods is discussed, such as the comparable uncontrolled price method, the cost-plus method and the transactional net margin method, in calculating the arm's length premium rate. Administrative practice in Norway dealing with captives in the oil industry is the point of departure for this discussion.
Book Synopsis Adkisson's Captive Insurance Companies by : Jay Adkisson
Download or read book Adkisson's Captive Insurance Companies written by Jay Adkisson and published by iUniverse. This book was released on 2006 with total page 372 pages. Available in PDF, EPUB and Kindle. Book excerpt: A captive insurance company is, in a nutshell, an insurance company formed by a business owner to insure the risks of the operating business. The operating business pays premiums to the captive, and the captive insures the risks of the operating business. A captive is much more than an exotic form of self-insurance: It is the creation of a new insurance company that has the potential to grow from being a mere captive into a full-blown insurance company seeking to profit from underwriting the risks of others. Adkisson's Captive Insurance Companies provides a basic introduction to captives and their benefits, including: utilize your own experience ratings; recapture underwriting profits; underwrite exposed risks and deductibles; access the reinsurance markets; and transfer wealth between generations. This book also provides a unique look at the wealth transfer, accumulation and preservation advantages of captives, as well as an overview of the types of captives, taxation of captives, and captive domiciles.
Book Synopsis U.S. Captive Insurance Law by : F. Hale Stewart
Download or read book U.S. Captive Insurance Law written by F. Hale Stewart and published by iUniverse. This book was released on 2015-02-18 with total page 225 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is the first book on captive insurance which informs the reader whether or not he should form a captive insurance company, how to run it along with an explanation of the tax issues associated with running a property and casualty insurance company. In addition, the reader is taken through an entire case law history of captive insurance to better enable him to understand the issues related to forming a captive insurance company. New with this edition is a lengthy section by Beckett G. Cantley addressing special IRS considerations about which the captive owner and/or practitioner should be aware. These include the applicability of certain judicial and statutory anti-avoidance doctrines applied by the IRS and courts to disallow certain tax benefits associated with captive transactions that exploit the Internal Revenue Code in a manner not intended or contemplated by Congress.
Book Synopsis Current Tax Issues with Captive Insurance Companies by : Beckett G. Cantley
Download or read book Current Tax Issues with Captive Insurance Companies written by Beckett G. Cantley and published by . This book was released on 2018 with total page 7 pages. Available in PDF, EPUB and Kindle. Book excerpt: Large U.S. companies have been forming captive insurance companies since the 1950s. In general, such large captives are formed for one of three main reasons. First, some companies are unable to obtain necessary insurance coverage. For example, certain nuclear power companies formed a captive named Nuclear Electric Insurance Limited, because they could find no other insurance coverage. Second, some companies seek to obtain cheaper insurance. For example, the trucking market is currently “hardening” (premiums are increasing), leading to trucking companies forming captives. Third, some companies seek to gain more control over their current insurance program. The insurance code offers a small insurance company a strategic advantage: Internal Revenue Code (IRC) § 831(b) allows insurance companies with less than $1.2 million in premiums to be taxed on their investment earnings rather than on their gross income. As a simple example, suppose a small insurance company had $500,000 in income but earned 5 percent on its total portfolio earning $25,000 for the year. The company would use the $25,000 figure as their gross income figure for the year. A captive can also be formed offshore and still be deemed a captive, provided it makes an IRC § 953(d) election agreeing to be taxed as a domestic company. For many large captives, forming offshore may provide a great deal of flexibility not found onshore. However, it should be noted that the Internal Revenue Service (IRS) is currently spending a great deal of time focused on offshore tax enforcement. Recently, the IRS refused to issue a positive private letter ruling to a number of foreign captives seeking 831(b) status, which may be an indication of tougher IRS scrutiny in this area. Thus, while a compliant captive should ultimately have nothing to fear from operating internationally, there is at least some chance that doing so may result in some additional compliance costs if it gets caught up in the IRS dragnet. This article will: (1) provide a brief history of captive insurance companies; (2) outline key requirements for captive insurance including insurance risks, risk shifting, risk distribution, and reinsurance; and (3) discuss certain IRS enforcement areas in captives, including excessive premiums and IRC § 831(b) tax shelter issues.
Book Synopsis Taxation of Property and Casualty Insurance Companies by : United States. Congress. Senate. Committee on Finance
Download or read book Taxation of Property and Casualty Insurance Companies written by United States. Congress. Senate. Committee on Finance and published by . This book was released on 1983 with total page 298 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis U.S. Captive Insurance Law by : F. Hale Stewart JD LLM CAM CWM CTEP
Download or read book U.S. Captive Insurance Law written by F. Hale Stewart JD LLM CAM CWM CTEP and published by iUniverse. This book was released on 2011-01-04 with total page 237 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is the first book on captive insurance which thoroughly examines the relevant issues associated with starting a captive insurance company. Part I begins with a description of the companies most likely to benefit from a captive program. This is followed by a detailed outline and explanation of the formation process and ends with an overview of the tax issues encountered by a property and casualty insurance company. Part II presents the first in-depth historical analysis of the entire history of U.S. captive insurance case law. It begins with the reserve cases of the early 20th century and is followed by the flood plane cases of the 1950s, the I.R.S. victories of the 1980s, the taxpayer victories of the 1990s and the I.R.S. safe harbor Revenue Rulings of the early 2000s. With over 950 footnotes and 40 sources, this is the most complete treatment of captive insurance to date.
Book Synopsis Captive Insurance Deskbook for the Business Lawyer by : David J. Slenn
Download or read book Captive Insurance Deskbook for the Business Lawyer written by David J. Slenn and published by American Bar Association. This book was released on 2018 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: To help lawyers decipher the intricacies of captive insurance, this guidebook begins with a discussion of types of captives and addresses how to approach whether a captive makes sense for a business owner. The book focuses on various aspects of the captive's operation and management--from taxation, special uses, and regulation to eventual exit and potential tax litigation issues. Captive insurance covers legal and non-legal practice areas such as taxation (domestic, foreign, state, and local), insurance (regulatory, coverage, and reinsurance), securities, commercial transactions, employee benefits, tax controversy, actuarial science, underwriting, and more.
Book Synopsis The Second Insurance Tax Seminar by : Federal Bar Association. Section of Taxation
Download or read book The Second Insurance Tax Seminar written by Federal Bar Association. Section of Taxation and published by . This book was released on 1990 with total page 90 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Tax Treatment of Workers' Compensation Funds (pooled Self-insurance Funds) by : United States. Congress. Joint Committee on Taxation
Download or read book Tax Treatment of Workers' Compensation Funds (pooled Self-insurance Funds) written by United States. Congress. Joint Committee on Taxation and published by . This book was released on 1987 with total page 26 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Modern Captive Insurance by : Matthew Queen
Download or read book Modern Captive Insurance written by Matthew Queen and published by . This book was released on 2020-10-07 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Insurance is a sophisticated financial vehicle that can be best understood through the lens of risk management. Experiencing dramatic growth, captive insurance is owned and controlled by its insureds, pooling the risks of its owners. Captive insurance provides businesses with unmatched flexibility regarding coverage, claims, premium, and control, while also offering advantages such as lucrative dividends and innovative financing techniques. This state-of-the-art guide traces the development of small captive insurance and addresses how to set up and properly manage a captive. Modern Captive Insurance: A Legal Guide to Formation, Operation, and Exit Strategies, begins with an overview of what captive insurance is and detail the advantages in setting up a captive for a range of different business situations. Chapters explain how to incorporate and start up a new captive insurance program, including basic terminology and the roles different professionals play in running captive programs. Captive insurance is an intricate yet effective risk management strategy. For guidance in properly establishing a captive, the authors address critical issues evaluated by the IRS, such as risk shifting and distribution, and explore ethical considerations arising out of off-shore captive management, such as how to identify money laundering red flags and how to properly manage the investments of reserves. Modern Captive Insurance takes an in-depth look at the topics and issues that are common in insurance and in businesses, but are often handled differently for captives, such as: Financial statements, investments, and financial ratings Policy drafting and coverage Risk pools and structuring the pooling arrangement to be valid Federal, state and local taxation Tax-exempt organizations Risk retention groups (RRP) Reinsurance, and more Table of Contents Chapter 1: Captive Company Formation Chapter 2: Captives and Capitalists Chapter 3: Risk Pools Chapter 4: Financial Statements, Investments, and Financial Ratings Chapter 5: Policy Drafting and Coverage Chapter 6: Underwriting and Claims Reserving Chapter 7: Federal Income Tax and Captives Chapter 8: State and Local Captive Insurance Issues Chapter 9: Tax-Exempt Organizations and Captive Insurance Chapter 10: Risk Retention Groups and How They Work Chapter 11: Reinsurance Chapter 12: Workers' Compensation and the Grand Bargain Chapter 13: Employee Benefits Conclusion Table of Cases and Index
Book Synopsis The Business Owner's Definitive Guide to Captive Insurance Companies by : Peter J. Strauss
Download or read book The Business Owner's Definitive Guide to Captive Insurance Companies written by Peter J. Strauss and published by Forbesbooks. This book was released on 2017-07-06 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: MANAGE YOUR RISK IN A MORE EFFICIENT WAY What if you could insure the risks of your business, reduce your out of-pocket expenses, and create another source of revenue? Sounds too good to be true, right? With The Business Owner's Definitive Guide to Captive Insurance Companies, Mr. Strauss shows that, by utilizing a captive insurance company, this is not only possible but also a lot easier than you'd imagine. As one of America's top corporate, tax, and risk management attorneys, Mr. Strauss provides readers with true insight on the key sophisticated planning techniques used by small business owners who implement captive insurance companies. You'll learn the fundamentals and history of captive insurance and how this technique can provide numerous benefits to your business. This book will provide you with the insight on how to: -reduce out-of-pocket expenses; -increase cash flow; -insure more of the risks of your business; -protect personal and business assets from lawsuits; and -select the appropriate manager for your captive insurance company. Creating a captive insurance company may sound daunting, but with Mr. Strauss's guidance you can navigate the legal maze and utilize this valuable strategy with ease. Don't miss out on crucial out-of-pocket savings, and create more liquidity in a more tax-efficient manner. Take steps today and reap the benefits of captive insurance!
Book Synopsis The Complete Idiot's Guide to Starting a Home-based Business by : Barbara Weltman
Download or read book The Complete Idiot's Guide to Starting a Home-based Business written by Barbara Weltman and published by . This book was released on 2007 with total page 364 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Research Handbook on International Insurance Law and Regulation by : Julian Burling
Download or read book Research Handbook on International Insurance Law and Regulation written by Julian Burling and published by Edward Elgar Publishing. This book was released on 2012 with total page 883 pages. Available in PDF, EPUB and Kindle. Book excerpt: 'Global insurance and its rapidly evolving law and regulation demands international research. To this aim, the Handbook offers a truly international collection of essays. Highly renowned experts analyze the key topics currently under international discussion and development. While representing a diversity of national jurisdictions, the focus lies on the largest insurance jurisdictions (USA, UK and Germany) but newly important jurisdictions like Brazil and China are considered as well a most valuable and important contribution to international insurance law literature.' Manfred Wandt, Director of the Insurance Law Institute, Goethe-University Frankfurt, Germany 'This Research Handbook is published at an opportune time. A global review of insurance law and regulation is underway. Much reform happens locally with little reference to developments elsewhere and this Research Handbook brings the strands together. It is a comprehensive review by distinguished authors from different backgrounds including both leading academics and practitioners. They consider the definitions of insurance, its economic underpinnings, comparative law and regulations, actual and proposed reforms, the effects on underwriting and claims and how insurance is studied and taught. Good laws and regulation benefit the market and its customers. Bad laws and regulation do the opposite. This book is required reading for all involved in the reform process.' David Hertzell, Law Commissioner 'Globalisation has had no greater impact in the commercial world than on insurance, the law which governs it and the risks it seeks to address. Those who inspired this publication and the contributing authors, are to be thanked for providing such a necessary and useful reference source. It covers so much of what insurance professionals need to be aware of in the insurance/law world of the twenty first century.' Michael Gill, President of the International Insurance Law Association Given its economic importance, insurance is a field that has been underserved as an area of academic study. This detailed book provides much needed coverage of insurance law and regulation in its international context. Produced in association with Lloyd's, it draws on the expertise both of academics and practising lawyers. Containing 30 comprehensive chapters, it provides in-depth studies on key areas, such as the role of international organisations, the judicial interpretation of insurance contract clauses and transnational regulatory recognition. It also provides thorough introductions to important jurisdictions, including the EU, US and Japan as well as focusing on newly emerging economies such as China and Brazil. Specialist topics covered include regulation by and of Lloyd's, the tort of bad faith in the US, microinsurance and takaful insurance. This well-documented resource will appeal to academics and students in insurance law and regulation, policymakers and private practice lawyers. The book also aims to stretch the imagination of anyone with an interest in insurance law and regulation, providing detailed analysis and avenues for further investigation.
Book Synopsis Arm’s Length Transaction Structures by : Andreas Bullen
Download or read book Arm’s Length Transaction Structures written by Andreas Bullen and published by IBFD. This book was released on 2011 with total page 925 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book examines the authority to restructure and to disregard controlled transactions based on the arm's length principle. The book, thus, examines the outer limits of the adjustment authority granted by the arm's length principle as opposed to its core area of application (price adjustments).
Book Synopsis Schwarz on Tax Treaties by : Jonathan Schwarz
Download or read book Schwarz on Tax Treaties written by Jonathan Schwarz and published by Kluwer Law International B.V.. This book was released on 2021-09-28 with total page 870 pages. Available in PDF, EPUB and Kindle. Book excerpt: Schwarz on Tax Treaties is the definitive analysis of tax treaties from United Kingdom and Irish perspectives and provides in-depth expert analysis of the interpretation and interaction of those treaty networks with the European Union and international law. The sixth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, Irish domestic and treaty developments, international and EU law, including: Covered Tax Agreements modified by the BEPS Multilateral Instrument; judicial decisions of Ireland, the UK and foreign courts on UK and Irish treaties; Digital Services Tax; treaty binding compulsory arbitration; Brexit and the EU-UK Trade and Cooperation Agreement; taxpayer rights in exchange of information; taxpayer rights in EU cross-border collection of taxes; attribution of profits to permanent establishments; and EU DAC 6 Disclosure of cross-border planning. Case law developments including: UK Supreme Court in Fowler v HMRC; Indian Supreme Court in Engineering Analysis Centre of Excellence Private Limited and Others v CIT; Australian Full Federal Court in Addy v CoT; French Supreme Administrative Court in Valueclick; English Court of Appeal in Irish Bank Resolution Corporation v HMRC; JJ Management and others v HMRC; United States Tax Court in Adams Challenge v CIR; UK Tax Tribunals in Royal Bank of Canada v HMRC; Lloyd-Webber v HMRC; Esso Exploration and Production v HMRC; Glencore v HMRC; McCabe v HMRC; Padfield v HMRC; Davies v HMRC; Uddin v HMRC; English High Court in Minera Las Bambas v Glencore; Kotton v First Tier Tribunal; and CJEU in N Luxembourg I, and others (the ‘Danish beneficial ownership cases’); État belge v Pantochim; College Pension Plan of British Columbia v Finanzamt München; HB v Istituto Nazionale della Previdenza Sociale. About the Author Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian and Irish Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He is a Visiting Professor at the Faculty of Law, King’s College London University. He has been listed as a leading tax Barrister in both the Legal 500, for international corporate tax, and Chambers’ Guide to the Legal Profession, for international transactions and particular expertise in transfer pricing. He has been lauded in Who’s Who Legal, UK Bar for his ‘brilliant’ handling of cross-border tax problems. In Chambers Guide, he is identified as ‘the double tax guru’ with ‘extraordinary depth of knowledge and experience when it comes to tax treaty issues and is a creative thinker and a clear and meticulous writer’.
Book Synopsis Audits of Property and Liability Insurance Companies by :
Download or read book Audits of Property and Liability Insurance Companies written by and published by . This book was released on 2000 with total page 380 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Federal Income Taxation of Property and Casualty Insurance Companies by : Ernst & Young LLP
Download or read book Federal Income Taxation of Property and Casualty Insurance Companies written by Ernst & Young LLP and published by John Wiley & Sons. This book was released on 1996-04-30 with total page 548 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is the first book to address the special rules that apply to the taxation of all property and casualty insurance companies, including life insurance companies with property/casualty insurance operations. It covers the special rules that apply to the taxation of captive insurance companies in addition to the general rules that are usually applicable to a captive insurance company. At the same time, it examines the fact that many healthcare organizations are now considered to be insurance companies and will be taxed as such under all the various healthcare reform proposals. Includes a sample tax return for property and casualty insurance companies, Form 1120PC, and guidance on how to read and review a property and/or casualty company annual report.
