hstaxblog.blogspot.com
Hale Stewart Law Tax Law Blog: The Flood Plane Cases, Part I
http://hstaxblog.blogspot.com/2011/10/flood-plane-cases-part-i.html
Hale Stewart Law Tax Law Blog. Thursday, October 13, 2011. The Flood Plane Cases, Part I. Although we think that the first important legal battle for captive insurance occurred during the economic substance cases that started in the 1970s, the reality is two cases from the 1950s ( US. v. Weber. And Consumers Oil Corp v. US. First, let's set the stage by explaining what caused the need to create one of these captives in the first place: the Trenton Flood of 1955. Worse yet, there had been little rain to e...
hstaxblog.blogspot.com
Hale Stewart Law Tax Law Blog: The Economic Family Cases: Conclusion
http://hstaxblog.blogspot.com/2011/12/economic-family-cases-conclusion.html
Hale Stewart Law Tax Law Blog. Saturday, December 17, 2011. The Economic Family Cases: Conclusion. This will be the last blog posting of this year; I will resume the captive section of this blog's writing with the Humana case after the first of the year. To all, Merry Christmas and Happy New Year. The captive cases can be broken down into two segments: the economic family cases - where the IRS gained trial momentum for their theories, and the Humana. Here are the salient points moving forward. The servic...
hstaxblog.blogspot.com
Hale Stewart Law Tax Law Blog: What Was The IRS' Beef With Captives?
http://hstaxblog.blogspot.com/2011/10/what-was-irs-beef-with-captives.html
Hale Stewart Law Tax Law Blog. Saturday, October 8, 2011. What Was The IRS' Beef With Captives? Starting in the mid-1970s, and continuing through the UPS case, the IRS fought captives tooth and nail. Over the course of these cases, they advanced three different legal arguments against captive insurance: the economic family argument, the nexus of contracts and the assignment of income doctrine. Point number four is a bit weak, as the courts focused on the amounts paid from the contingency fund rather than...
hstaxblog.blogspot.com
Hale Stewart Law Tax Law Blog: US CFC Rules: What Income Is Included?
http://hstaxblog.blogspot.com/2013/11/us-cfc-rules-what-income-is-included.html
Hale Stewart Law Tax Law Blog. Sunday, November 17, 2013. US CFC Rules: What Income Is Included? The CFC rules regarding income inclusion have to thread a very small needle. On one hand, they need to prevent US taxpayers from moving offshore, thereby taking advantage of a technical reading of the US tax code that prevents taxation of non-US (foreign) corporations ( see discussion here. Before moving forward, be advised: below is a general summation. Foreign personal holding company income. Is designed to...
hipak.blogspot.com
Business in Pakistan: Oil's Price Drop Hurting Canada
http://hipak.blogspot.com/2015/04/oils-price-drop-hurting-canada.html
Business and Banking in Pakistan. Stock Market Trading and Trends. Monday, April 13, 2015. Oil's Price Drop Hurting Canada. Several of Canada’s central bankers have publicly stated that oil’s price drop will negatively impact their economy. Deputy Governor Timothy Lane was the first to do so. In a speech on January 13. He concluded that, lower oil prices are likely, on the whole, to be bad for Canada. Bank of Canada Central Governor Poloz echoed this sentiment in a March 30 Financial Times interview.
halestewartlaw.com
Captives - The Law Office of Hale Stewart, JD, LLM832.330.4101
http://www.halestewartlaw.com/captives.html
The Law Office of Hale Stewart, JD, LLM. Hale Stewart Law Blog. Where Finance, Economics and Law Meet. A captive insurance company is defined as a "wholly-owned insurance subsidiary." More specifically, it's an insurance company that you own. Captive insurance is handled by my captive insurance management company, HS Captive Management. Hale Stewart Law Blog.
dailykos.com
Daily Kos: bonddad
http://www.dailykos.com/blog/bonddad
Subscribe to hide ads. More Stories ». More Stories ». More Stories ». More Stories ». More Stories ». Readers and Book Lovers. More Stories ». More Stories ». More Stories ». More Stories ». More Stories ». More Stories ». More Stories ». Check out our slate of Daily Kos-endorsed candidates. Sign the pledge: I will Get Out The Vote to defeat Trump. Donald Trump is the Republican nominee, which is frightening.We must make sure his hateful rhetoric does not even come close. See All 7 Campaigns ». Housing ...
assetprotectionlawyerinhouston.com
Houston Asset Protection Attorney Hale Stewart - Welcome
http://www.assetprotectionlawyerinhouston.com/index.html
Houston Asset Protection Attorney Hale Stewart. When Should you Plan? On Fraudulent Transfer Law. On January 26th, at 10 AM CST, I'll be giving a webinar on fraudulent transfer law. Attendance is free. You can sign up at this link. What is Asset Protection? Asset protection is a legal method of reducing your exposure to various types of risks by placing assets into various protected structures. For example, did you ever wonder why both Pepsi and Coca-Cola have bottling divisions? The first is bankruptcy.
hstaxblog.blogspot.com
Hale Stewart Law Tax Law Blog: The IRS' War on Captives; Humana, Part III
http://hstaxblog.blogspot.com/2012/01/irs-war-on-captives-humana-part-iii.html
Hale Stewart Law Tax Law Blog. Saturday, January 14, 2012. The IRS' War on Captives; Humana, Part III. For background, please see Humana Part I. And Humana Part II:. Also of importance was the Crawford case,. Which was the only economic family case that had separate and extremely divided ownership of the captive. There is a second point from the court's reasoning that should be mentioned. From the case:. Note: Only a member of this blog may post a comment. Subscribe to: Post Comments (Atom). The Economic...