Author: Jay Adkisson
Publisher: iUniverse
ISBN: 0595422373
Category : Business & Economics
Languages : en
Pages : 372
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Book Description
A captive insurance company is, in a nutshell, an insurance company formed by a business owner to insure the risks of the operating business. The operating business pays premiums to the captive, and the captive insures the risks of the operating business. A captive is much more than an exotic form of self-insurance: It is the creation of a new insurance company that has the potential to grow from being a mere captive into a full-blown insurance company seeking to profit from underwriting the risks of others. Adkisson's Captive Insurance Companies provides a basic introduction to captives and their benefits, including: utilize your own experience ratings; recapture underwriting profits; underwrite exposed risks and deductibles; access the reinsurance markets; and transfer wealth between generations. This book also provides a unique look at the wealth transfer, accumulation and preservation advantages of captives, as well as an overview of the types of captives, taxation of captives, and captive domiciles.
Author: F. Hale Stewart
Publisher: iUniverse
ISBN: 1491750146
Category : Business & Economics
Languages : en
Pages : 225
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Book Description
This is the first book on captive insurance which informs the reader whether or not he should form a captive insurance company, how to run it along with an explanation of the tax issues associated with running a property and casualty insurance company. In addition, the reader is taken through an entire case law history of captive insurance to better enable him to understand the issues related to forming a captive insurance company. New with this edition is a lengthy section by Beckett G. Cantley addressing special IRS considerations about which the captive owner and/or practitioner should be aware. These include the applicability of certain judicial and statutory anti-avoidance doctrines applied by the IRS and courts to disallow certain tax benefits associated with captive transactions that exploit the Internal Revenue Code in a manner not intended or contemplated by Congress.
Author: Robert Danon
Publisher: Kluwer Law International B.V.
ISBN: 9403540354
Category : Law
Languages : en
Pages : 1053
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Book Description
It is well known that intercompany financing arrangements have become increasingly subject to scrutiny in contexts of applying transfer pricing and anti-tax avoidance-related rules. With contributions by more than 50 leading global transfer pricing and international tax experts from law firms, multinational enterprises, academia, and tax administrations, this book provides unparalleled insights into the application of the Arm’s Length Principle to different types of financial transactions, application of anti-avoidance rules to various intra-group financial arrangements as well as the business value creation process and the dispute management landscape that underlie intra-group financial transactions. With in-depth analysis of the legislation and market developments that fuel the diverse range of financing options available to market participants – and loaded with practical examples and case studies that cover the legal and economic considerations that arise when analysing intra-group finance – the contributors examine such topics and issues as the following: national anti-abuse rules applicable to financial transactions; tax treaty issues; role of credit ratings and impact of implicit support; loans, cash pooling, financial guarantees; transfer pricing aspects of performance guarantees; ‘mezzanine’ financing; considerations for crypto financing; impact of crises situations such as COVID-19; how treasury operations can be structured in a group and the decision-making process involved; how hedges offset or mitigate risks; how to apply the arm’s length principle to factoring and captive insurance transactions; comparability analysis for various transactions; special considerations for transactions carried out by a permanent establishment; EU state aid and its interaction with transfer pricing rules; dispute prevention and resolution tools under the OECD, UN, and EU frameworks; and developing countries’ perspectives, focusing on Brazil, India, and South Africa. Given the challenges facing taxpayers and tax authorities alike, this book will prove an immeasurably valuable reference guide to support tax practitioners, tax administrations, and tax scholars in developing standards and policies in dealing with intra-group financing issues.
Author: F. Hale Stewart JD LLM CAM CWM CTEP
Publisher: iUniverse
ISBN: 1450277950
Category : Business & Economics
Languages : en
Pages : 237
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Book Description
This is the first book on captive insurance which thoroughly examines the relevant issues associated with starting a captive insurance company. Part I begins with a description of the companies most likely to benefit from a captive program. This is followed by a detailed outline and explanation of the formation process and ends with an overview of the tax issues encountered by a property and casualty insurance company. Part II presents the first in-depth historical analysis of the entire history of U.S. captive insurance case law. It begins with the reserve cases of the early 20th century and is followed by the flood plane cases of the 1950s, the I.R.S. victories of the 1980s, the taxpayer victories of the 1990s and the I.R.S. safe harbor Revenue Rulings of the early 2000s. With over 950 footnotes and 40 sources, this is the most complete treatment of captive insurance to date.
Author: Jay Adkisson
Publisher: McGraw Hill Professional
ISBN: 0071505474
Category : Business & Economics
Languages : en
Pages : 337
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Book Description
Strategies that are effective and legal for putting one’s assets safely out of reach In today’s increasingly litigious world, the shielding of assets has become a prominent issue for financial planners, business owners, and high-net-worth individuals. Asset Protection details methods that are both legally and morally legitimate for protecting one’s assets from creditors, lawsuits, and scams. Bringing economic common sense and legitimacy to an area that is drowning in gimmickry, two of today’s top lawyers examine the fundamental issues in this growing area, avoiding dense legalese to make the book accessible to anyone. Asset Protection covers everything readers want to know about: Establishing an effective asset protection program Today’s most popular, established strategies Newer strategies that are still being resolved by the courts
Author: Louis L. Straney
Publisher: John Wiley & Sons
ISBN: 0470601574
Category : Business & Economics
Languages : en
Pages : 210
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Book Description
The first complete, expert guide to securities and investment fraud Filled with expert guidance for detection and prevention of all kinds of securities fraud and investment misconduct, Securities Fraud helps you identify red flags of fraud and offers practical ways to detect and prevent it. Written by a Wall Street professional with three decades of experience spanning the most critical period of our financial markets This book challenges classic fraud theories, describing how to dismantle information silos that permit fraudsters to conceal their activities. Begins with an overview of the evolution of securities regulation and the impact of securities fraud Offers real cases and examples which illustrate recurring themes and red flags Provides the first guide of its kind to offer a complete look at the various kinds of securities fraud and investment misconduct Securities Fraud is the essential guide you need for a bird's-eye view of fraud that may be taking place even now within your own organization and with your portfolio.
Author: John M. Cunningham
Publisher: Wolters Kluwer
ISBN: 145488049X
Category : Law
Languages : en
Pages : 3536
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Book Description
This essential resource enables you to negotiate, draft, and fine-tune LLC operating agreements for all basic types of LLCsand—in every U.S. jurisdiction! It delivers exclusive guidance on all 10 stages of the LLC formation process, and comes with a CD-ROM packed full of valuable material, including complete agreements, forms, and clauses all ready for immediate use. Newly expanded to two volumes, theand Fourthand Edition of Drafting Limited Liability Company Operating Agreements is the only limited liability company formbook and practice manual that addresses the entire process of planning, negotiating and drafting LLC operating agreements, and handling LLC formations. Providing hands-on guidance directly from John M. Cunningham, one of the acknowledged leaders in the field, Drafting Limited Liability Company Operating Agreements, Fourthand Edition, ensures that youand’re prepared to handle all legal and tax aspects of the LLC formation process for member-managed, manager-managed, single-member, and multi-member LLCs, including: Fiduciary issues and other critical business organization law issues facing the managers of multi-member LLCs Multi-member LLC partnership tax issues The unique legal and tax issues confronting owners of single-member LLCs Hidden issues in drafting articles of organization The complex issues of legal ethics when representing two or more clients in forming multi-member LLCs Only Drafting Limited Liability Company Operating Agreements, Fourthand Edition fully covers: The 10 main stages of the LLC formation process, providing detailed, practice-oriented comments on each and“Red flagsand” spotlighting common pitfalls and risks in LLC formation Key federal tax materials, including the and“Check-the-Box Regulationsand” and the IRSand’s guidelines on the application of the Self-Employment Tax to LLC members The current text of the Delaware Limited Liability Company Act And Drafting Limited Liability Company Operating Agreements, Fourthand Edition includes: All of the general-purpose model operating agreements you are likely to need to form both single-member and multi-member LLCs, designed for use in all 50 states and accompanied by line-by-line instructions Guidance through the entire, complex maze of legal, tax, and drafting issues An all-new section on protecting clientsand’ assets through LLCs Valuable exhibits, including a master table and various subsidiary tables of the Delaware Limited Liability Company Act provisions relevant to LLC formations Plus! Every clause, form, and complete agreement is on CD-ROMand—to speed the formation process and help save you time. To assist in your LLC formation practice, youand’ll also find a comprehensive survey of the rapidly expanding body of federal and state LLC case lawand—complete with clear summaries of the cases and indexes by both state and subject matter. Newly updated and expanded, Drafting Limited Liability Company Operating Agreements, Fourthand Edition, delivers all the forms, agreements and expert guidance every LLC practitioner should have on hand. and
Author: Joshua M. Korman
Publisher: World Scientific
ISBN: 9814277304
Category : Medical
Languages : en
Pages : 526
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Book Description
Plastic surgeons go through extensive training to become excellent clinicians, but they often end up learning how to practice the business of plastic surgery through trial and error. This unique book, targeted specifically at plastic surgeons and other physicians, seeks to address this glaring oversight and provide guidance from career selection through retirement. It offers many different perspectives, while covering a multitude of topics including the latest know-how on building and maintaining one's website, marketing and monitoring a practice for increased productivity, asset protection, building a surgical suite, and the development of medical inventions. The Business of Plastic Surgery features notable authors in the fields of medicine, law, finance and technology who provide valuable wisdom and expertise
Author:
Publisher:
ISBN:
Category : Tax expenditures
Languages : en
Pages : 1004
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Book Description
Author: David Cay Johnston
Publisher: Penguin
ISBN: 1101216220
Category : Business & Economics
Languages : en
Pages : 356
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Book Description
Now updated with a new prologue! Since the mid-1970s, there has been a dramatic shift in America's socioeconomic system, one that has gone virtually unnoticed by the general public. Tax policies and their enforcement have become a disaster, and thanks to discreet lobbying by a segment of the top 1 percent, Washington is reluctant or unable to fix them. The corporate income tax, the estate tax, and the gift tax have been largely ignored by the media. But the cumulative results are remarkable: today someone who earns a yearly salary of $60,000 pays a larger percentage of his income in taxes than the four hundred richest Americans. Pulitzer Prize-winning investigative reporter David Cay Johnston exposes exactly how the middle class is being squeezed to create a widening wealth gap that threatens the stability of the country. By relating the compelling tales of real people across all areas of society, he reveals the truth behind: • "Middle class" tax cuts and exactly whom they benefit. • How workers are being cheated out of their retirement plans while disgraced CEOs walk away with millions. • How some corporations avoid paying any federal income tax. • How a law meant to prevent cheating by the top 2 percent of Americans no longer affects most of them, but has morphed into a stealth tax on single mothers making just $28,000. • Why the working poor are seven times more likely to be audited by the IRS than everyone else. • How the IRS became so weak that even when it was handed complete banking records detailing massive cheating by 1,600 people, it prosecuted only 4 percent of them. Johnston has been breaking pieces of this story on the front page of The New York Times for seven years. With Perfectly Legal, he puts the whole shocking narrative together in a way that will stir up media attention and make readers angry about the state of our country.