Taxation and Reinsurance of Vehicle Related Protection Products

October 6-7, 2008

Overview and Objectives

Terri Harris, IRS Motor Vehicle Technical Advisor, spoke at the Consumer Credit Insurance Association Annual Meeting in May 2006 and confirmed what some of us had already begun to notice. In a very well-presented speech, she reiterated the IRS’ belief that not all producer affiliated reinsurance companies are bad, but she also stated that the IRS has a new theory regarding “abusive” reinsurers, namely, applying a “transfer pricing analysis” to judge whether the reinsurance transaction constituted an arm’s length transaction.
 
 Concurrently, the IRS began to use this theory and other approaches to question §501(c)(15) and §831(b) reinsurers. Following a finding that a reinsurer was not an insurance company, the §953(d) election was deemed invalid, and the reinsurer was deemed a controlled foreign corporation. Recalculated taxes and penalties are being assessed, with particularly adverse penalties for those who do not have a determination letter.
 
 The IRS has continued to press the transfer pricing theory, but the cases appear to be moving slowly through the IRS procedures regarding audits, conferences, appeals, etc.

Learning Objectives:
 
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Agenda

Participant List

Fee Schedule

Venue

Book Your Room

Print Version

Event & Registration Details

Venue: The Westin DFW Airport Hotel Irving, Texas.  Click to book your room

Early Bird Deadline: September 19th. Click here to register

Materials: We provide a conference notebook of support materials. This book will not only guide you through the conference, it will serve as a continuing reference source for your bookshelf.

Prerequisites and Advance Preparation: None

Program Level: Advanced

Instruction Method: Group - Live

CPE Credits: 12

Terms & Conditions: Payment of the conference fee must be received prior to the conference. An early bird discount can be applied if registration and payment are received by the early bird deadline. 

Cancellations:  A replacement can be sent from your company if you are unable to attend, or, if we receive a written cancellation request at least two (2) weeks prior to the conference date, you will receive a refund less a $100 administrative fee per registrant. No refunds will be issued on cancellation requests received within the two (2) weeks prior to the conference.

Accommodations:  Attendees are responsible for making their own hotel reservations.  Discounted room rates at the hotel are only available until September 5th.  The discounted rate is $189.  After the deadline,  rooms will be charged at the published corporate room rate and subject to availability.

Contact Info:  If you have any questions about the arrangements, complaints, or other needs, please call Angie Johnson at (817) 788-8121 ext. 238 or email angie.johnson@creditre.net

CreditRe is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be addressed to the National Registry of CPE Sponsors, 150 Fourth Avenue North, Suite 700, Nashville, TN 37219-2417. Web site: www.nasba.org