News & Analysis — Results 1 – 5 of 6:
... Judge Mark Holmes ruled that payments made to the Avrahamis by their micro captive, Feedback, amounted to taxable ... the scope of certain tax elections. Feedback insured the Avrahamis’ Arizona jewellery stores and shopping centres against chemical and ...
Captive Investments Scrutinized Following Key Tax Court Ruling
... Tax Court’s decision in Benyamin Avrahami and Orna Avrahami v. Commissioner of International Revenue and its ... nbsp;However, despite the potentially chilling effect of Avrahami, taxpayers engaging in microcaptive transactions should remain confident ...
“Captive Insurance May Help In A Pandemic, But Caution Is Key”
Captive Insurance May Help In A Pandemic, But Caution Is Key By Patrick McCann (July 2, 2020) As a result of the national pandemic created by COVID-19, small business owners across the country are learning the painful lesson that their traditional ...
Tax Court Taketh Away While Congress Giveth Back
... ’ continued support for small captives should be that while Avrahami may represent a ‘what not to do’ roadmap ...
“IRS Announcement Likely Overstates True Impact of Captive Insurance Settlement” in Bloomberg Tax
... .S. Tax Court cases that involved small captive insurance companies (Avrahami v. Commissioner, Reserve Mechanical Corp. v. Commissioner, (appeal pending in ...
Tax Blog/Blawg — One result:
... captive insurance arrangements hadn’t been muddied enough after Avrahami v. Commissioner , on June 18, 2018, the U.S. Tax ...
Additional Documents — All 2 results:
CH_Karter Kirkpatrick and Steele in FCdS Legal_05 15 18.pdf
... under Section 831(b) of the Internal Revenue Code. In Avrahami, the Tax Court upheld the IRS’ disallowance of premium deductions ... Although the IRS had reason to cheer the outcome in Avrahami, the case also provided taxpayers much-needed judicial guidance on ...
CH_Karter for Business Insurance_02 15 18.pdf
... the U.S. Tax Court in Benyamin Avrahami and Orna Avrahami v. Commissioner of Internal Revenue issued its ... professional advisers. Despite the potentially chilling effect of Avrahami, taxpayers engaging in microcaptive transactions should remain confident ...