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The materials on the Eversheds Sutherland website are for general information purposes only and do not constitute legal advice. While reasonable care is taken to ensure accuracy, the materials may not reflect the most current legal developments. Eversheds Sutherland disclaims liability for actions taken based on the materials. Always consult a qualified lawyer for specific legal matters. To view the full disclaimer, see our Terms and Conditions or Disclaimer section in the footer. Services Captives Insurance Insurance Taxation Tax Key contacts Saren Goldner Partner New York, United States P. 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Eversheds Sutherland Entities are constituted and regulated in accordance with relevant local regulatory and legal requirements. The use of the name Eversheds Sutherland, is for description purposes only and does not imply that the member firms or their controlled, managed or affiliated entities are in a partnership or are part of a global entity. The responsibility for the provision of services to the client is defined in the terms of engagement between the instructed firm and the client. For information on Konexo please also see the Legal Notices page of this website ATTORNEY ADVERTISING - Prior results do not guarantee a similar outcome. Unless otherwise indicated, attorneys at Eversheds Sutherland (US) LLP are not certified by the Texas Board of Legal Specialization.

Micro-Captive CCA on Withholding Tax

August 01, 2024

United States

Captive Insurance Company Reports

In the August 2024 edition of Captive Insurance Company Reports, Eversheds Sutherland attorneys Saren Goldner and Bruce Wright further review the IRS’ Chief Counsel Advice 202422010 and analyze issues that arise with characterization of a micro-captive and its transactions, including the impact on withholding tax.

The materials on the Eversheds Sutherland website are for general information purposes only and do not constitute legal advice. While reasonable care is taken to ensure accuracy, the materials may not reflect the most current legal developments. Eversheds Sutherland disclaims liability for actions taken based on the materials. Always consult a qualified lawyer for specific legal matters. To view the full disclaimer, see our Terms and Conditions or Disclaimer section in the footer.

Saren Goldner

Partner

New York, United States

P. Bruce Wright

Of Counsel

New York, United States

Latest Insights

legal updates
Illinois tax increases part two: Digital asset privilege tax, prediction markets, NOL carryover limitations, and more
legal updates
Georgia’s corporate governance reform: Key changes under HB 1185
legal updates
Illinois tax increases part one: Digital services taxes
legal updates
Federal insurance developments: Recent activity and key issues to watch

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UK employment law training
virtual | June 16, 2026
Nordic (Denmark, Finland, Norway and Sweden) employment law training
virtual | June 23, 2026
Introduction to Swiss employment law
virtual | September 10, 2026
UAE - Employment law in the Dubai International Financial Centre

Tabs Label

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legal updates

June 02, 2026

Illinois tax increases part two: Digital asset privilege tax, prediction ma...

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legal updates

June 02, 2026

Georgia’s corporate governance reform: Key changes under HB 1185

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legal updates

June 01, 2026

Illinois tax increases part one: Digital services taxes

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legal updates

May 29, 2026

Federal insurance developments: Recent activity and key issues to watch

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Eversheds Sutherland is the name and brand under which the members of Eversheds Sutherland Limited (Eversheds Sutherland (International) LLP and Eversheds Sutherland (US) LLP) and their respective controlled, managed or affiliated firms and the members of Eversheds Sutherland (Europe) Limited and Eversheds Sutherland (Africa) Limited (each an "Eversheds Sutherland Entity" and together the "Eversheds Sutherland Entities") provide legal or other services to clients around the world. Eversheds Sutherland Entities are constituted and regulated in accordance with relevant local regulatory and legal requirements. The use of the name Eversheds Sutherland, is for description purposes only and does not imply that the member firms or their controlled, managed or affiliated entities are in a partnership or are part of a global entity. The responsibility for the provision of services to the client is defined in the terms of engagement between the instructed firm and the client. For information on Konexo please also see the Legal Notices page of this website
ATTORNEY ADVERTISING - Prior results do not guarantee a similar outcome.
Unless otherwise indicated, attorneys at Eversheds Sutherland (US) LLP are not certified by the Texas Board of Legal Specialization.

Micro-Captive CCA on Withholding Tax

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