Insurance Coverage & Recovery
More Insurance Coverage & Recovery Articles
Contracts
Managing Risk With Effective Contract Provisions
Effective risk management is an important goal in any contract negotiation, particularly when the parties’ performance under the contract exposes them to potential third party claims for bodily injury, property damage, and other alleged injuries. One tool in the bag of effective risk...
Read MoreInsurance Coverage & Recovery
When Standard Pollution Insurance Policies Aren’t Enough
Real estate development, construction, mining and energy development share a set of risks ranging from construction accidents, earth movement and collapse to environmental clean-up. While these risks may be anticipated in some measure, the fast-changing regulatory landscape exacerbates them....
Read MoreInsurance Coverage & Recovery
Beyond The Bright-Line Test: Rent-A-Center v. Commissioner – Long-Awaited U.S. Tax Court Decision Provides More Heat Than Light On What Constitutes “Insurance” Between Related Parties
In 1977, IRS issued Rev. Rul. 77-316,[1] which held that when a corporate parent insures risks with a wholly owned subsidiary, the transaction per se cannot be characterized as insurance for federal tax purposes because the risk shifting and risk distribution that the U.S. Supreme Court has...
Read More