In December 2015, the Protecting Americans from Tax Hikes Act of 2015 (PATH Act) passed and increased the previous premium limitation from $1.2 million to $2.2 million—beginning after 2016. It also added an annual adjustment for inflation to the premium limitation. As a part of the inflation adjustments for 2018, the IRS increased the 2018 [...]
What comes to mind when someone talks to you about forming a captive? If your mind immediately goes to protecting yourself from marauding pirates, then - believe it or not - you’re on the right track! What we’re really talking about is captive insurance companies, and they are believed to have originated with ship owners [...]
A captive insurance company (or “captive”) is a licensed insurer generally established to meet the risk management needs of a specific company or group of companies. The risk management benefits are the primary reason for their formation, but the tax benefits can also be valuable. A captive must be licensed as an insurance company through [...]
In the recently released Notice 2016-66, the IRS identified micro-captive transactions as "transactions of interest" under Reg. 1.6011-4(b)(6). The mandate requires parties involved in certain Internal Revenue Code Section 831(b) arrangements to disclose the transactions to the IRS. In late December 2016, the IRS released Notice 2017-08 to extend the disclosure deadline from January 30, 2017 [...]
