• IRS Rules on Revocation of Section 953(d) Election
  • November 23, 2017 | Author: Saren Goldner
  • Law Firm: Eversheds Sutherland (US) LLP - New York Office
  • Captive Insurance Company Reports

    The Internal Revenue Code (IRC) permits a foreign property and casualty insurance or reinsurance company to elect to be treated as a domestic company (i.e., a US company) if, in general, (a) it is treated as an insurance company under Subchapter L of the IRC (i.e., the provisions that govern insurance companies) and (b) it is a controlled foreign corporation.

    In their article for the December 2017 issue of Captive Insurance Company Reports, Eversheds Sutherland Partners P. Bruce Wright and Saren Goldner describe what happens in the event an election is made.