Change font size
It is currently Sat May 27, 2017 3:04 am
Adkisson's Captive Insurance Companies
Untitled 1

 

Adkisson's Captive Insurance Companies  Real Experience Means Over 100 Captives Formed Since 1998      
Riser Adkisson LLP
The Captive Insurance Law Firm
Newport Beach, CA - Athens, GA
info @ risad.com or 949-200-7753
Formation & Licensing -- Second Opinions -- Ongoing Review -- Litigation of Captive Issues

 

Captive Insurance News and Events

IRS Treaty Country Listing as of April 2008

News and upcoming events involving captive insurance companies and alternative risk management, including association meetings, educational forums, etc. Please send us your news, press release, or meeting information to add to our list! Send to jay <at> captivebook.com

IRS Treaty Country Listing as of April 2008

Postby Riser Adkisson LLP » Sun Dec 14, 2008 8:14 am

SOURCE: Foreign Insurance Excise Tax - Audit Technique Guide, April 2008, as found at http://www.irs.gov/businesses/small/art ... 63,00.html NOTE: This document is not an official pronouncement of the law or the position of the Service and can not be used, cited, or relied upon as such. This guide is current through the publication date. Since changes may have occurred after the publication date that would affect the accuracy of this document, no guarantees are made concerning the technical accuracy after the publication date.

----------------------------------------------------------------



Treaty Country Listing as of April 2008
QUALIFIED TREATIES
Treaty Country Effective Date Limited by Anti-Conduit Provision
Cyprus 1-1-86 Yes
Finland 1-1-91 Yes
France 2-1-96 Yes
Germany 1-1-90 Yes
India 1-1-91 Yes
Ireland 1-1-98 Yes
Israel 1-1-95 Yes
Italy 1-1-85 Yes
Japan 1-1-05 Yes
Luxembourg 1-1-01 Yes
Mexico 1-1-94 Yes
Netherlands 1-1-94 Yes
Sweden 1-1-96 Yes
Switzerland 1-1-98 Yes
Spain 1-1-91 Yes
United Kingdom 1-1-04** Yes***

UNQUALIFIED TREATIES
Treaty Country Effective Date Limited by Anti-Conduit Provision
Hungary 1-1-80 to Current No
Romania 1-1-74 to Current No
United Kingdom 1-1-75 to 12-31-03** No
USSR * 1-1-76 to Current No
* In effect for Armenia, Azerbaijan, Belarus, Georgia, Kazakhstan, Kyrgyz Republic, Moldova, Tajikistan, Turkmenistan, Ukraine, and Uzbekistan. Although Russia entered into a separate treaty with the United States in 1992, it does not contain an insurance premium excise tax exemption.

** Effective date is extended one year to 1-1-05 for U.K. entities which elect to have the provisions of the old treaty apply for the first 12 months.

*** The transaction is exempt unless the policies are entered into as a part of a conduit arranged to reduce the tax due.
My book: Adkisson's Captive Insurance Companies: An Introduction to Captives, Closely-Held Insurance Companies and Risk Retention Groups
My website: http://www.captiveinsurancecompanies.com
My e-mail: jay >>>at<<< risad.com
My phone: 900-200-7284
User avatar
Riser Adkisson LLP
The Captive Insurance Lawfirm - http://www.risad.com
The Captive Insurance Lawfirm - http://www.risad.com
 
Posts: 135
Joined: Sun Nov 23, 2008 8:41 pm
Location: Admitted in Arizona, California, Nevada, Oklahoma and Texas

Return to Captive Insurance News and Events

cron

User Control Panel

Login



Active Captive Management


Adkisson's Captive Insurance Companies

Who is online

In total there is 1 user online :: 0 registered, 0 hidden and 1 guest (based on users active over the past 5 minutes)
Most users ever online was 397 on Thu Jun 28, 2012 4:03 am

Users browsing this forum: No registered users and 1 guest

Birthdays

No birthdays today