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Justifying The Exclusion Of Insurance, Jeffrey H. Kahn
Justifying The Exclusion Of Insurance, Jeffrey H. Kahn
Scholarly Publications
No abstract provided.
Hedging The Irs -- A Policy Justification For Excluding Liability And Insurance Proceeds, Jeffrey H. Kahn
Hedging The Irs -- A Policy Justification For Excluding Liability And Insurance Proceeds, Jeffrey H. Kahn
Scholarly Publications
Uncertainty about tax results is an ever-present obstacle to business transactions despite the extensive number of Internal Revenue Code sections and Treasury Regulations. Some insurance companies now provide an insurance product to protect taxpayers against adverse tax consequences from proposed transactions. Ironically, this new insurance product, labeled “tax insurance,” poses uncertain tax consequences itself This Article argues that if the adverse tax consequences arise (that is, the taxpayer has additional tax liability) and the insurance company is contractually required to cover that liability, the tax insurance proceeds are not includable in the insured’s gross income. As part of the reasoning …