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Tax Risks Challenge Small Captive Insurers

by Marc T. Finer , William J. Kambas , and Ryan M. LoRusso A captive insurance company is an insurance company formed primarily or exclusively to insure the risks of one or more affiliated businesses. Many larger companies form captive insurance companies for the purpose of insuring against risk which...

Recourse or Non-Recourse? The Limited Scope of Partnership Liability Regs

by Marc T. Finer and Ryan M. LoRusso Albert Einstein once said “[t]he hardest thing in the world to understand is the income tax." Nowhere is this truer in the Internal Revenue Code than in the context of the recourse versus nonrecourse liability rules of Subchapter K (partnership tax...