Reserve Mechanical Corp. v. CIR

  1. May 13, 2022

    10th Circ. Affirms Captive Insurer's Tax Liability On Premiums

    A captive insurer owes tax on premiums it received from a mining company after the Tenth Circuit on Friday affirmed a U.S. Tax Court decision determining it wasn't in the business of insurance and couldn't claim preferential tax treatment.

  2. July 09, 2021

    4 Federal Tax Cases To Watch In 2021's 2nd Half

    Over the next six months, courts may explore substantive administrative law challenges to microcaptive and conservation easement tax regulations, the future of an estate planning technique, the intersection of tax and insurance laws, and the scope of IRS summons powers. Here, Law360 looks at four federal tax cases worth monitoring in the second half of 2021.

  3. May 04, 2021

    10th Circ. Judge Looks Askance At Microcaptive's Premiums

    A Tenth Circuit judge questioned Tuesday whether a company embroiled in a dispute with the IRS over its use of a microcaptive insurance structure could justify charging $400,000 in premiums for a policy worth $1 million. 

  4. July 06, 2020

    Captive Insurer Not Eligible For Exemption, 10th Circ. Told

    The Anguilla-based captive insurer of an Idaho mining company isn't entitled to a tax exemption because its arrangements didn't constitute insurance, the U.S. told the Tenth Circuit on Monday, urging it to affirm a decision from the U.S. Tax Court.

  5. February 28, 2020

    10th Circ. Urged To Allow Captive Insurer Tax Deduction

    A U.S. Tax Court decision to deny a tax deduction to the captive insurer of an Idaho mining company undermined years of insurance practice, captive-insurance associations for 10 states said in a recent amicus brief for the Tenth Circuit.

  6. February 24, 2020

    Tax Court Confused Over Insurance Industry, Co. Tells 10th Circ.

    The U.S. Tax Court misunderstood the nature of the insurance industry when it ruled erroneously that a captive insurer of an Idaho hazardous mining company didn't qualify for a tax deduction, the insurance company has told the Tenth Circuit.