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Tax count conclusions

Alan Fine of Brown Smith Wallace discusses the questions he feels are raised by the Reserve Mechanical case and the takeaways for captive insurers

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The aftermath

In August, the US Tax Court released its decision in the Avrahami case.

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Take notice

The Protecting Americans from Tax Hikes (PATH) Act of 2015 made significant changes to Section 831(b) of the Internal Revenue Code and also included new annual reporting requirements for electing captive insurance companies.

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Compliance considerations

Alan Fine of Brown Smith Wallace explains three key options to maintain compliance with changes to Section 831(b)

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Friends of the court

In January 2014, the US Tax Court handed down a pro-taxpayer case related to the federal income tax deductibility of insurance premiums paid to a commonly controlled captive insurance company...

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The more things change, the more the IRS looks to blame

In January 2014, the US Tax Court released its long awaited decision in Rent-A-Center v Commissioner, addressing the deductibility for federal income tax purposes of premium payments made by brother/sister entities to a commonly controlled captive insurance company.

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