Insurance Coverage & Recovery
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Insurance 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...
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Understanding The Hidden Risks Of Life Insurance: Due Diligence For Policy Holders And Fiduciaries
Immediate cash needs at death range from general living expenses to buying out a business partner or providing funds to pay estate taxes. But imagine opening a letter one day from your insurance company to find that your equity-based life insurance policy may lapse due to lack of funding. Despite...
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FDIC Issues Advisory Statement Regarding D&O Insurance Policies, Exclusions And Indemnification For Civil Money Penalties
On October 10, 2013, the Federal Deposit Insurance Corporation (the “FDIC”) issued an advisory statement in response to its concern that there has been an increase in exclusionary terms contained in directors and officers liability insurance policies issued to depository...
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