The federal government spending package titled the Further Consolidated Appropriations Act, 2020 and signed into law on December 20, 2019, averted a government shutdown that would have begun on December 19 and funds the government through September 30, 2020. The Act also includes various tax provisions. The tax legislation, which was the product of intense negotiations between congressional leaders and the White House, extends through 2020 some of the tax incentives for individuals and businesses, known as extenders, that had already expired or that were due to expire at the end of 2019.
In three recent cases, the U.S. Tax Court found related-party insurance companies (captive insurance companies) didn’t sufficiently distribute risk to allow the insured parties to deduct their premium payments. In an article recently published by Bloomberg Tax, Laurie Bizzell of Bennett Thrasher LLP analyzes the cases, the court’s historical view and the IRS’ position to find there is no conclusive definition of risk distribution.