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Captive Insurance Company Tax Articles

Captive Taxation Articles & News
(click title to read articles)

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Caution: Make sure you do small 831(b) qualifying captives conservatively and reasonably today for primarily risk management reasons or the IRS on review is likely to object to use of the substantial tax benefits afforded insurance companies - read this article to learn more.

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IRS Noose Starting to Tighten on Sham Risk Pools

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Estate and Tax Planning with Captives 

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US Captive Insurance Company Income Tax Audit Guidelines, Captive Foreign Corporation Tax Audit Guidelines, and Captive Liquidation Tax Audit Guidelines Issued by the IRS

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Documenting the Non-Tax Business Purpose and Economic Substance of 831(b) Captives – Impact of the New Codified Economic Substance Doctrine

Captive Review October 2012 issue article by our Managing Director, Tom Cifelli, discussing The Affordable Care Act's new Economic Substance Test as applied to Captive Design coupled with an analysis of the IRS Revenue Ruling 2005-40.

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Self Procurement Premium Taxes - Application to Out of State Captives, Impact of NRRA, and Related Concerns

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Purchasing Insurance From Unlicensed Insurers - Can States Tax or Restrict Sale of Insurance by Captives Not Licensed in the State?, reprinted from captive.com and Risk & Insurance

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Benefits of 831(b) Captive Insurance Companies (reprinted from Journal of Accountancy, April 2013

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Multiple Captive Insurance Company Planning and Impact on 831(b) and other Tax Attributes 
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Updated Article on Multi-Captive Applications - US Control Group Rules
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Coming Tax, Legal and Financial Controversies Impacting Small 831(b) Captives
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Dodd Frank Act - Nonadmitted Reinsurance Reform Act Impact on State Taxes and Potential Re-Domestication of Non-US Captives ... (click here for a related position paper issued October 6, 2011 by a law firm taking a pro-captive viewpoint)
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The Growth in 831 (b) Captives by Middle Market Companies Leads New Captive Formations, by Captive Review Research Staff, June 2011
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831 B Tax Advantaged Small Captive Insurance Companies - Financial and Estate Tax Planning Benefits for Closely Held Businesses, by Tom Cifelli, March 24, 2012
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New Economic Substance Tax Test Impact on 831(b) Captives 
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831(b) captive premium levels - use caution in pricing to prevent tax audit adjustments, republished March 2012. Editor Note: This article has two sides - it raises the issue of whether a deduction for premiums paid by an insured are "reasonable" and will withstand audit as ordinary and necessary; it also touches on implications if a captive is audited. The authors however are not tax experts. 
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State Retaliatory Self-Procurement Premium Tax Confusion - Constitutional Nexus Analysis and Proposed Solution, by Tom Cifelli, May 2012, Captive Review.

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Learn why Panama has become an attractive tax haven for general foreign business, and why it may become a popular captive domicile in future years by clicking here.

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Understanding IRS 501 (c) (15) Captive Insurance Companies and IRS Audit Guidelines as of 2006 for Captive Insurance Company Tax Audits

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IRS Audit and Denial of Deductions for Abusive Offshore Business Protection, Life and Annuity Insurance Arrangements that Failed to Meet US Tax Requirements


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