Selected Issues and Developments in Federal Income Taxes
(Co-authored with Michael C. Warren).
This article focuses on certain federal income tax issues that can arise when an insurance company is in receivership and particularly when the insurance company is a member of a consolidated group. It discusses the importance of federal income tax considerations for the receiver (even in a situation where the insurer has significant loss carryforwards) and certain recent developments at the IRS. The article also addresses the considerations in two fairly common scenarios involving the filing (or lack thereof) of the respective federal income tax returns and describes a variety of options and tools to obtain IRS assistance and resolve the insurer’s tax situation.
The Insurance Receiver, Volume 24, Number 2.