A number of provisions included in the Senate’s tax reform bill, H.R. 1 (the Senate Bill) would impact the insurance sector. Many of the provisions would affect only the life insurance industry. Others affect property & casualty (P&C) insurance companies. Still others affect both life and P&C insurance companies.
Tax Reform: Insurance Provisions—Spotlight on Property & Casualty Insurers
Posted In Tax Reform, Uncategorized
Tags: active insurance assets, affiliated corporations, amortization, captive insurance, cash value, discounted loss reserves, diverse portfolio, dividends, excise tax, international provisions, net operating losses, offshore captive insurance companies, P&C insurance, passive foreign investment company provisions, PFIC provisions, private P&C carriers, public P&C carriers, section 172(d)(1), section 810, special rule, untaxed earnings
Kristen E. HazelKristen E. Hazel has extensive experience representing clients in US and international aspects of federal tax matters, including international acquisitions and divestitures, international joint ventures, and capital plan design and implementation. Her work includes both inbound and outbound transactions. Kristen is the co-chair of the Firm's Captive Insurance Affinity Group. She regularly counsels clients with respect to the tax aspects of organizing, operating and defending captive insurance companies. Read Kristen Hazel's full bio.
Michael J. WilderMichael J. Wilder focuses his practice on corporate and international tax issues. He has extensive experience in structuring corporate mergers and dispositions, spin-offs, liquidations, cross-border transfers and financing instruments, as well as in the areas of consolidated returns, bankruptcy and insolvency tax matters. Michael represents clients in seeking private letter rulings from the Internal Revenue Service (IRS) and in handling audit and appeals matters. Michael is the leader of McDermott’s Corporate Tax Practice. Read Michael Wilder's full bio.
Michael F. KelleherMichael F. Kelleher represents corporate taxpayers in complex federal income tax controversies, transfer pricing and insurance tax matters. In the tax controversy arena, Michael represents clients in pre-audit planning, audits before the Internal Revenue Service (IRS) Appeals Office and in litigation. He has extensive experience with alternative dispute resolution (ADR) procedures, including fast-track and post-appeals mediation. Read Michael Kelleher's full bio.
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