Search results: 831(b)
831(b) market prepares for extended fight against latest IRS regulations
Despite the Internal Revenue Service making some concessions in its long-awaited final version of 831(b) regulations, particularly in relation to loss ratio thresholds, industry commentators believe it continues to target micro captives unfairly, with one legal challenge already filed.
IRS finalises 831(b) regulations, concedes on loss ratio criticism
The Internal Revenue Service has finalised the long-awaited update to its 831(b) regulations which sees the loss ratio for micro captives considered as “listed transactions” reduced to 30%, while the loss ratio for “transactions of interest” has been reduced to 60%.
IRS increases 831(b) annual premium limit to $2.85m
The Internal Revenue Service (IRS) will increase the annual premium limit for captives taking the 831(b) election to $2.85m for 2025.
No significant changes expected to IRS 831(b) regulation
The decision by the Internal Revenue Service (IRS) to include micro captive regulation in its 2024-2025 priority guidance shows that the IRS is still planning to “move forward” with its proposed regulations, according to Bailey Roese, partner at Dentons, Bingham Greenebaum.
Legislative bill in works in response to current 831(b) proposals
The MiniCap Coalition, which includes members such as the 831(b) Institute, is exploring introducing a legislative bill in response to current Internal Revenue Service (IRS) proposals regarding micro-captives.
RMC Group win gives hope for future 831(b) battles – ZMF’s Matthew Reddington
The jury verdict in favour of captive management company, RMC Group and its president and CEO, Raymond Anker, against the Internal Revenue Service (IRS) highlights there are ways micro captives can be successful in cases that have historically gone against them.
831(b) captives “high priority area” for IRS as it completes 2024 Dirty Dozen
The Internal revenue Service (IRS) has wrapped up its Dirty Dozen list for 2024 with micro captives taking the 831(b) tax election remaining a key focus area for the Service.
Captive manager RMC Group wins 831(b) promoter case against the IRS
Captive management company RMC Group and its president and CEO, Raymond Ankner, have won an important case against the Internal Revenue Service in the United States, with the assistance of law firm, ZMF Law.
IRS continues war on 831(b) captives: When will it end?
The Internal Revenue Service (IRS) remains at a stand-off with captives making the 831(b) tax election, and there is no indication of an imminent conclusion, with some observers believing the IRS is purposely drawing out the process.
Captive USA 2024 Part II: More 831(b) captives to close, cells continue to prosper
Further 831(b) captives in the United States are expected to shut down as a result of the proposed regulations from the Internal Revenue Service (IRS), while the popularity of cells is expected to grow further.
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