Bringing tax and insurance together

Asher Harris conducts a boutique law practice, which focuses on the United States tax aspects of risk management and global insurance. The unique aspect of the practice is the high-level understanding of both tax and risk management, which facilitates the integration of these two highly complex fields.

Because of his experience with one of the world’s most prominent law firms, and with one of the most highly respected reinsurance companies, Mr. Harris gives clients access to the type of expertise normally only available in large law firms, together with the personal attention, responsiveness, and cost-efficiency of a small law practice.

Clients include large multi-nationals corporations, both American and non-U.S., as well as some of the world’s largest insurance and reinsurance companies.

INQUIRE

Please submit inquiries to info@asherharris.com
I have worked with Asher for more than two decades, and I have always found him to be creative and careful in designing innovative risk transfer structures and customized solutions. Asher combines a best-in-class level of tax expertise with a deep understanding of insurance and reinsurance. I highly recommend him!
John Doucette, Reinsurance ExecutiveCEO, Amynta Risk Solutions
I have worked with Asher for more than two decades, and I have always found him to be creative and careful in designing innovative risk transfer structures and customized solutions. Asher combines a best-in-class level of tax expertise with a deep understanding of insurance and reinsurance. I highly recommend him!
John Doucette, Reinsurance ExecutiveFormer President and CEO of Reinsurance, Everest Reinsurance Company
Asher Harris is the person you want to tackle complex situations. He brings insight, clarity and creativity to every problem he encounters. He cuts through technical matters and helps focus on the important issues so that time, money and resources can be directed effectively. Asher is a partner in debating strategic issues and a sounding board to vet alternate strategies. He always delivered what he promised and made sure we had answers even to the questions we didn't ask.
Heidi Hutter, CEOThe Black Diamond Group
I have worked with Asher on corporate and personal tax issues since 2006. His advice is always timely, practical and creative. He is well plugged in to current tax trends so I was always confident that his advice was appropriate to the situation.
Len GoldbergFormer CEO, Greenlight Reinsurance Company
We have used Asher's services for several projects related to United States FET, and we have always found him reliable and responsive, and highly knowledgeable in the area of United States insurance tax. I highly recommend him!
Jari Ostrovskij, Tax Council, Corporate TaxIf P&C Insurance
  • The information contained in this Web site is provided for informational purposes only, and should not be construed as legal advice on any subject matter.
  • No recipients of content from this site, clients or otherwise, should act or refrain from acting on the basis of any content included in the site without seeking the appropriate legal or other professional advice on the particular facts and circumstances at issue from an attorney licensed in the recipient’s state. The content of this Web site contains general information and may not reflect current legal developments, verdicts or settlements. Asher Harris expressly disclaims all liability in respect to actions taken or not taken based on any or all the contents of this site.
  • Any information sent via Internet e-mail or through the Asher Harris Web site is not secure and is done so on a non-confidential basis. The transmission of the Asher Harris site, in part or in whole, and/or communication with Asher Harris via Internet e-mail through this site does not constitute or create an attorney-client relationship between Asher Harris and any recipient(s).
  • Mr. Harris does not necessarily endorse, and is not responsible for, any third-party content that may be accessed through this Web site.
  • None of the materials on this Website have been written to be used, and cannot be used, for the purpose of (i) avoiding tax-related penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or tax-related matter(s). Any taxpayer should seek advice regarding his or her particular facts and circumstances from an independent tax advisor.

Law Office of Asher Harris 2024   |   All Rights Reserved  |  Site design KWGraphicsandWeb

Scroll to Top

A captive insurance company is an insurance company that is organized and owned by the parties that own the insured enterprise.  Under certain circumstances, insuring risks through a captive insurance company can be a more tax-efficient risk management technique than purchasing insurance from a third-party insurer.

State self-placement taxes are imposed by a state when risks within the state are covered by insurance that is not purchased from an insurer licensed within the state. There is no nationally accepted terminology for these taxes, which can be called self-placement taxes, self-procurement taxes, or taxes on independently-procured insurance. Under federal law, only the “home state” can impose these taxes. For any insurance program, the determination of the “home state”, and determining the scope of the taxes, can be highly complex.

The United States imposes a federal excise tax, known as FET, on insurance premiums paid to non-US insurance companies on risks that are located in the United States. The tax rate is 4% for direct non-life insurance, and 1% for reinsurance or life insurance.

A closing agreement is an agreement entered into between a foreign insurance company and the Internal Revenue Service.  By entering into a closing agreement, the insurance company agrees to comply with certain requirements of US tax law, such as filing returns and consenting to the right of the IRS to audit the company. In exchange, the IRS agrees that American companies that buy insurance from that insurance company are allowed to assume that the insurer is eligible for an exemption from FET under a tax treaty.