Insurance Tax

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Overview

Honigman’s Insurance Tax Practice Group provides services ranging from assisting for-profit and tax-exempt clients in complying with U.S. state and federal tax filing requirements in multi-jurisdictional insurance transactions, to designing and implementing tax-efficient U.S. inbound and outbound structures and joint venture arrangements. 

Our attorneys advise both individuals and companies regarding the U.S. and foreign tax implications of cross-border transactions, including matters related to tax treaties, withholding taxes, Subpart F/anti-deferral rules, foreign tax credits and offshore bank accounts. 

Honigman is also adept in examining the deductibility and taxation of premiums, return premiums, retrospective assessments/credits, policyholder dividends and loss reserves involving captive insurance companies under U.S. federal, state and local tax laws. Our attorneys regularly counsel clients on the special tax rules applicable to stock insurance companies, mutuals, reciprocals, risk retention groups and their owners/insureds, including those associated with direct procurement/surplus lines taxes, federal excise tax and unrelated business income tax, as well as domestication, “micro” captive and entity classification elections. 

As a complement to our extensive planning and advice capabilities, we have vast experience in representing taxpayers in connection with Internal Revenue Service examinations and penalty abatement situations. Our attorneys also prepare documentation in support of tax return and financial statement positions, including matters involving FIN 48, FAS 5 and APB 23.

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