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Insurance Companies and Products
Caplin & Drysdale
Insurance Companies and Products

Caplin & Drysdale advises and represents life insurance companies and property and casualty insurance companies on a broad range of issues, including company-level tax issues under subchapter L of the Internal Revenue Code, subpart F issues for controlled foreign corporations that are insurance companies, and the U.S. taxation of U.S. and foreign policyholders of life insurance, annuity, and accident and health insurance contracts.

Representative Engagements

  • When a property and casualty insurance company with substantial investment activities sought advice as to whether it qualified as an insurance company for U.S. tax purposes, Caplin & Drysdale issued an opinion.

  • When a U.S. life insurance company sought advice as to whether contracts issued to nonresident aliens affected its status as a life insurance company for U.S. tax purposes, Caplin & Drysdale issued an opinion.

  • When a U.S. life insurance company sought advice as to whether fees assessed against annuity contracts constituted taxable distributions to policyholders, Caplin & Drysdale issued an opinion.

  • When a U.S. life insurance company was under examination by the IRS as to whether the reserves of its foreign branch were recognized for U.S. tax purposes, Caplin & Drysdale helped them reach a favorable settlement with the IRS Appeals Office.

  • When a U.S. life insurance company was under examination by the IRS as to the allowance of its losses from reinsurance transactions, Caplin and Drysdale helped them reach a favorable settlement with the IRS Appeals Office.
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