Elizabeth Erickson
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Elizabeth Erickson provides legal counsel on complex civil tax controversies, including tax litigation and transfer pricing matters. She has extensive experience in resolving domestic and international tax matters at all stages of dispute, including Internal Revenue Service examinations, administrative appeals, and litigation in the US Tax Court and district courts. She has advocated for clients before the Internal Revenue Service National Office, negotiated Advance Pricing Agreements with the Internal Revenue Service and other tax authorities, and resolved disputes through the Competent Authority process. Read Elizabeth Erickson's full bio.
IRS Rules Captive Reinsurance Arrangement Involving Retiree Medical Benefits Qualifies as Insurance for Federal Tax Purposes
By Brian Tiemann, Elizabeth Erickson, Kristen E. Hazel and Thomas M. Jones, PC on Jun 3, 2014
Posted In Health and Welfare Plans
On May 18, 2014, the Internal Revenue Service (IRS) ruled that an employer’s wholly owned captive insurance subsidiary could reinsure the employer’s retiree medical benefit risks and still qualify as insurance for federal tax purposes, even though the retiree medical reinsurance policy was the only business of the captive. The IRS held that the insured...
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