Validus Reinsurance, Ltd. v. USA

14-5081

May 26, 2015
IRS Can't Tax Foreign Reinsurance Policies, DC Circ. Says

The D.C. Circuit on Tuesday ruled that the Internal Revenue Service may not collect an excise tax on reinsurance policies between two foreign entities, saying there's no indication that Congress intended the tax to apply to completely foreign companies.
February 20, 2015
Foreign Reinsurance Out Of IRS Reach, DC Circ. Told

Validus Reinsurance Ltd. told the D.C. Circuit on Friday that an Internal Revenue Service rule seeking to tax reinsurance transactions between foreign companies is unconstitutional, urging the court to uphold a Washington, D.C., district court's sparse finding that federal law bars the practice.
October 15, 2014
DC Circ. Should Rein In Int'l Reinsurance Tax, Groups Say

Groups representing overseas insurance companies and brokers have asked the D.C. Circuit to expand the reasoning behind a district court's ruling that the Internal Revenue Service may not collect an excise tax on reinsurance policies between two foreign entities.
October 07, 2014
DC Circ. Told US Tax Power Stops At Foreign Retrocessions

Validus Reinsurance Ltd. on Friday urged the D.C. Circuit to uphold a February district court ruling that the Internal Revenue Service may not collect an excise tax on reinsurance policies between two foreign entities, saying that to do so is outside of the government's constitutional reach.