Captive Insurance Taxation: Compliance, Tax Reform and Section 953(d) Election

By Krysten Hambrook

Share A “Captive Insurance Company” is a closely held insurance company whose insurance business is primarily supplied and controlled by its owners. Captives provide operational, business and tax advantages to businesses and owners. While many captive insurance companies are domiciled off-shore in no- or low-tax jurisdictions, US taxpayers owning captives were generally taxed on their…

Fees Received for Endorsing Vendors Deemed to be UBTI

By Krysten Hambrook

In a recent decision on the “New Jersey Council of Teaching Hospitals v. Commissioner of Internal Revenue”, (2017) 149 T.C. No. 22, filed on December 20, 2017, the Tax Court found that fees received for recommending certain vendors did not qualify for any exceptions under Internal Revenue Service (“IRS”) rules and regulations with respect to unrelated…

What You Should Know About Your Plan’s ERISA Fidelity Bond Coverage

By Krysten Hambrook

As benefit plan auditors, common questions we receive from clients are – what does my ERISA fidelity bond cover? Who does it cover? And is the amount appropriate? The Employee Retirement Income Security Act of 1974 (“ERISA”) requires that every fiduciary of an employee benefit plan and every person who handles funds or other property…

S Corporations Subject to Three-Year Hold Period

By Krysten Hambrook

On March 1, 2018, the Treasury Department (TD) released Notice 2018-18, giving notice on its intentions on issuing regulations that will address the taxation of carried interest for “corporations.” Carried interest is an investment managers share of profits that they receive as a form of compensation for running a fund. The tax treatment in pass-through…

Understanding Non-Marital and Marital Property

By Krysten Hambrook

A divorce is a stressful process, especially when it comes to determining how parties divide their assets. The laws governing division of property in a marital dissolution vary by state. Currently, 41 states follow a process called equitable distribution, which divides assets and liabilities based on fairness and not equality. Other states, known as community…

Uniform Guidance Procurement Standards for Not-for-Profits

By Krysten Hambrook

2018 marks the start of the newest set of Uniform Guidance Procurement Standards – one of the biggest regulatory changes in years. Courtney Winters, CPA and Gianna Figurelli touch on the changes that not-for-profit organizations need to be aware of heading into 2018. More on Uniform Guidance These uniform guidance procurementstandards apply to the first…

Partnership Representative Role Under the New Audit Rules

By Krysten Hambrook

Partnership Representative Role Under the New Audit Rules Partnership Representative Background As a result of the passing of the Bipartisan Budget Act of 2015 (BBA) enacted into law on November 2, 2015, the current rules governing partnership audits will be replaced with a new audit regime. Under the new audit regime, the position of Tax…