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The IRS' War on Captives; UPS, Part I
UPS is the last case in the captive case saga. The IRS attempted to...
Hale Stewart Law Tax Law Blog -
Maritime Employers Can Face Punitive Damages Under General Maritime... insurancethoughtleadership.com
Maritime Employer Liability and Protection & Indemnity policies...
Most Popular Discussions
Bancroft: Insurance Company Wins Rights To Recover Books And Records From Insurance Manager
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Bancroft Life & Casualty ICC, Ltd., v. Intercontinental Mgt., Ltd., 2012 WL 19741 (3rd Cir. (Pa.), Slip Copy, Jan. 5, ...
Adkisson's Captive Insurance Companies captiveforum.com
Bancroft Life & Casualty ICC, Ltd., v. Intercontinental Mgt., Ltd., 2012 WL 19741 (3rd Cir. (Pa.), Slip Copy, Jan. 5, 2012) This case was not selected for publication in the Federal Reporter. Not for Publication in West's...

Chinese oil companies form joint captive captivereview.com
PetroChina and China National Petroleum Corporation (CNPC) signed an agreement on 4 January to establish a joint captive and have applied for approval from the China Insurance Regulatory Commission. The registered capital of...

Cell Company Guide captivereview.com
Bill Fitzpatrick,vice-president, insurance & risk management of DHL discusses writing premium into DHL’s captive, concerns for 2012 and an aim for more locally covered policies.

Rozin: Loss Of Income Policies With Return Of Premium Riders Used To Evade Taxes Results In Conviction Of Insured -- Law Firm Opinion...
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U.S. v. Rozin, ___ F.3d ____, 2012 WL 28643 (6th Cir. (Ohio), Jan. 6, 2012). Full Opinion at http://www.goo.gl/bQaAYCaduceus ...
Adkisson's Captive Insurance Companies captiveforum.com
U.S. v. Rozin, ___ F.3d ____, 2012 WL 28643 (6th Cir. (Ohio), Jan. 6, 2012) United States Court of Appeals, Sixth Circuit. UNITED STATES of America, Plaintiff–Appellee, v. Leif D. ROZIN, Defendant–Appellant. No. 11–3186....

The IRS' War on Captives; Humana, Part III
In this final installment of my look at the Humana case, I review the appellate court's reasoning in overturning the lower court.
Hale Stewart Law Tax Law Blog hstaxblog.blogspot.com
By way of background, in Part I, we looked at the background facts of the case, and learned that Human was a near-perfect set-up for a captive. The company was forced by business circumstances to form a captive, considered a...

Delaware: Mary Jo Lopez Retiring
Dear Members of the Delaware Captive Community,
For the past three years, I have thoroughly enjoyed and truly appreciated the ...

The IRS' War on Captives; Humana, Part II
In this second installment of our analysis of the case, we take an in-depth look at the court's reasoning which was later overturned on ...
Hale Stewart Law Tax Law Blog hstaxblog.blogspot.com
Below is an excerpt from my book on the Humana case. As an aside, if you get a bit confused by some of the terms used, you may want to go back and read some of the earlier posts on the captive cases; see the box on the right...

MOCIA Members to meet with MIssouri legislators
An educational seminar between members of MOCIA and legislators including the Committee on Insurance Policy will be held in Jefferson ...

The IRS' War on Captives; Humana, Part I
Humana marked the first solid taxpayer victory in captive litigation. It also provides some great points for now current practitioners ...
Hale Stewart Law Tax Law Blog hstaxblog.blogspot.com
Welcome back. I hope that everyone had a good holiday season. Before delving into the Humana case, note on the right side of the blog is a new box of links, titled "The Captive Cases." I've added links to each of the sections...

DomicileReports.com domicilereports.com
For Arizona, 2012 will be a landmark year for the state as a captive domicile. Arizona's first captive was licensed in 2002, and next year will mark the domicile's 10th year of success. Additionally, we have learned that Steve...

Security Life: Life Insurance Company Fails To Protect Its Collateral In PORC Arrangements Only To Watch The Collateral Later Disappear
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Security Life Ins. Co. v. Southwest Reinsure, Inc., 2011 WL 6382857 (D.Minn., Slip Copy, Dec. 20, 2011).Full Opinion at http ...
Adkisson's Captive Insurance Companies captiveforum.com
Security Life Ins. Co. v. Southwest Reinsure, Inc., 2011 WL 6382857 (D.Minn., Slip Copy, Dec. 20, 2011). United States District Court, D. Minnesota. SECURITY LIFE INSURANCE COMPANY OF AMERICA, Plaintiff, v. SOUTHWEST REINSURE,...

Microsoft Captive Approved For Benefit Risks
Article by Jerry Geisel of Business Insurance at http://www.businessinsurance.com/article/20111219/NEWS03/111219913?tags=%7C60%7C62%7C63 ...
Microsoft gets OK to expand benefit risks funded via captive insurer businessinsurance.com
WASHINGTON—The Labor Department has given Microsoft Corp. tentative authorization to expand benefit risks funded through the software giant's captive.

Section 831(b) Captives and the IRS: Underwriting and Audit Roulette | Insurance Thought Leadership insurancethoughtleadership.com
Much has been written about the financial and tax power of forming and operating a captive insurance company that qualifies for the tax benefits of section 831(b) of the Internal Revenue Code. But all too often, promoters of...

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The Captive Insurance Committee will provide support and education for lawyers who are involved with captive insurance ...
JOIN the Committee on Captive Insurance of the American Bar Association -- Non-Attorneys are Welcome as Affiliate Members apps.americanbar.org
Attorneys join at http://www.goo.gl/KgsdK -- Non-Lawyer Associates join at http://www.goo.gl/upjLf

Section 831(b) Captives and the IRS: Underwriting and Audit Roulette insurancethoughtleadership.com
Much has been written about the financial and tax power of forming and operating a captive insurance company that qualifies for the tax benefits of section 831(b) of the Internal Revenue Code. But all too often, promoters of this concept forget that each captive must be first and foremost a risk management tool with legitimate risks and properly priced premiums.
