Captive Insurance Companies, Part IV: Crackdown on Captive Insurance Abuses

Previous Posts in this Series Part I: What is a Captive Insurance Company? Part II: Types of Captives Part III: Benefits and Risks A captive insurance company manages its parent company’s business risks while providing it with substantial benefits. However, abuse of the tax benefits of captives – particularly small...

Captive Insurance Companies, Part III: Benefits and Risks

Previous Posts in this Series Part I: What is a Captive Insurance Company? Part II: Types of Captives Captive insurance companies provide businesses with savings opportunities, tax benefits, and greater flexibility in managing insurance needs. However, they are subject to pricing fluctuations, require significant capital, and pose some administrative challenges,...

Captive Insurance Companies, Part II: Types of Captives

Previous Posts in this Series Part I: What is a Captive Insurance Company? Captive insurance companies were created to enable corporations to establish subsidiaries that can insure the company’s own risks. The captive insurance industry has developed over the years and now includes a variety of forms and group structures....

Captive Insurance, Part I: What is a Captive Insurance Company?

Captive insurance companies were originally established to help businesses cover risks otherwise difficult to secure. They have expanded to include nearly every type of insurance. To protect themselves from certain risks, many businesses have formed subsidiary companies that provide them with insurance and risk-management services. Captive insurance companies are a...

What Constitutes “Willful” Failure to File An FBAR?

The willful failure to file an FBAR results in higher tax penalties than the nonwillful failure to do so. But how does the IRS determine that your failure to act was “willful”? The U.S. Government’s stringent foreign bank account reporting requirements are accompanied by horribly disproportionate penalties for failure to...

Failure to Report Foreign Account Results in Fine of 50% of Account Balance

Taxpayer liable for maximum willful FBAR penalty of 50% of account balance for failing to report foreign assets. The willful FBAR penalty battle rages on. The recent holding in Kimble vs. United States is a tremendous setback to taxpayers who have been delinquent with their foreign account reporting. Here is...