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📖 Description
This digital document is an article from The Tax Adviser, published by American Institute of CPA's on January 1, 1996. The length of the article is 757 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.
From the supplier: The US Court of Appeals for the Sixth Circuit reversed the Tax Court in Malone & Hyde, Inc. and found that the taxpayer was entitled to expense deductions because the payments to a subsidiary did not constitute a reinsurance contract. The Sixth Circuit applied the test for whether contracts in the captive insurance brother-sister companies context are insurance contracts for tax purposes. The court found no business purpose for an insurance contract and noted that risks were not shifted.
Citation Details Title: Captive insurance arrangements limited, not eliminated. Author: Kevin Owens Publication:The Tax Adviser (Magazine/Journal) Date: January 1, 1996 Publisher: American Institute of CPA's Volume: 27 Issue: n1 Page: 18(2)