This session will cover timely tax law updates from the IRS, federal courts and state departments of revenue and state courts. The session may be presented in a case study format, where we describe tax issues that may arise in the operation of a hypothetical captive, with application of current tax law changes to the captive and suggestions on how to tackle the problem.
Everyone is familiar with the IRS's recent focus on 831(b) captive audits, However, with most of those 831(b) captives already under audit, and many facing litigation with the government, the IRS could employ more agents with captive audit experience onto new insurance companies to examine. The proposed regulations identifying "micro captives" as listed transactions seem to indicate that the IRS is suspicious of ANY captive with loan-backs or loss ratios lower than 65%. And the IRS mentions in virtually every press release its interest in using the additional $60 billion in funding it has been allocated to increase audit rates, especially for corporations, partnerships and wealthy individuals. Could your captive be next?
Find out the latest activities in the captive tax world and learn how to best position your captive to survive an IRS audit with advice from tax practitioners who deal with the IRS every day.
Moderator:
- Bailey Roese, Dentons Bingham Greenebaum LLP, Partner
Speakers:
- Melissa L. Wiley, Partner, Lowenstein Sandler LLP
- Allan Autry, Johnson Lambert LLP, Tax Partner
- Dan Kusaila, Crowe LLP, Partner
Time: 11:15 a.m.-12:15 p.m. ET
Location: DoubleTree by Hilton in Burlington, Vermont - 870 Williston Rd, South Burlington, VT 05403
