On June 17, 2005, the Internal Revenue Service released Revenue Ruling 2005-40, in which the Service discussed whether, under four factual situations set forth in the Ruling, insurance exists for tax purposes. Richard Irvine, Partner, PricewaterhouseCoopers Bermuda, analyses recent internal revenue service rulings that throw light on what constitutes insurance for US tax purposes.
Originally printed in the 2006 edition of Bermuda Captive magazine.
