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Captive, also known as Fursuna in some releases, is a Canadian documentary film, directed by Mellissa Fung and released in 2021. The film documents the stories of three young Nigerian women who were abducted and held captive by Boko Haram, linking their experiences in part to her own past experience having been abducted by armed bandits in 2008 while covering the War in Afghanistan.
Movies with limited location choices and a small cast can struggle to engage their audiences, often resulting in a film looking bleak in areas. Captive (2020) sets a high standard with multi-layered characters that drive the story with tragic inner conflicts and characteristics.
The purpose of this Notice is to advise all participants in the captive insurance industry that the Oklahoma Insurance Department (OID), pursuant to 36 O.S. 6470.20 and 6470.34 has determined that on and after September 16, 2020, The capitalization requirement for certain special purpose captive insurers shall be $50,000.
Due to the pandemic and the tightening insurance market, more organizations are looking to captive insurance companies for financial flexibility and protection. By downloading the Captive Landscape Report, you receive the latest statistics, trends, and insights from across the industry to prioritize your captive strategies and achieve your goals.
The IRS encourages any taxpayer who has continued to engage in an abusive micro-captive insurance transaction to not anticipate being able to settle its transaction with the IRS or Chief Counsel on terms more favorable than previously announced settlement offers and that any potential future settlement initiative that the IRS may consider will require additional concessions by the taxpayer.
With this in mind, the IRS encourages taxpayers to consult an independent tax advisor if they participated in a micro-captive insurance transaction. These taxpayers should seriously consider exiting the transaction and not claiming deductions associated with abusive micro-captive insurance transactions, just like many other taxpayers did who were contacted by the IRS in March and July 2020.
For those taxpayers that do not exit the transaction and continue taking such deductions, the IRS will disallow tax benefits from transactions that are determined to be abusive and may also require domestic captives to include premium payments in income and assert a withholding liability related to foreign captives. The IRS will also assert penalties, as appropriate, including the strict liability penalty that applies to transactions that lack economic substance under sections 7701(o) and 6662(i). The IRS Office of Chief Counsel will continue to litigate these abusive transactions in Tax Court.
Abusive micro-captives have been a concern to the IRS for several years. The transactions first appeared on the IRS "Dirty Dozen" list of tax scams in 2014 and remain a priority enforcement issue for the IRS. In 2016, the Department of Treasury and IRS issued Notice 2016-66PDF, which identified certain micro-captive transactions as having the potential for tax avoidance and evasion. In March and July 2020, IRS issued letters to taxpayers who participated in a Notice 2016-66 transaction alerting them that IRS enforcement activity in this area will be expanding significantly and providing them with the opportunity to tell the IRS if they've discontinued their participation in this transaction before the IRS initiates examinations. Early responses indicate that a significant number of taxpayers who participated in these transactions have exited the transaction.
This summer, the IRS issued a new round of section 6112 letters to material advisors who filed with the IRS pursuant to Notice 2016-66. In addition, the IRS has deployed 12 newly formed micro-captive examination teams to substantially increase the examinations of ongoing abusive micro-captive insurance transactions.
Also, as part of IRS's continued focus in this area, the IRS has become aware of variations of the abusive micro-captive insurance transactions. Examples of these variations include certain Puerto Rico and offshore captive insurance arrangements that do not involve section 831(b) elections.
These variations appear to be designed and marketed with the express intent of avoiding reporting under Notice 2016-66 and yet perpetuating in some cases the same or similar abusive elements as abusive micro-captive insurance transactions. The IRS is aware of these abusive transactions and is actively working to counter their proliferation. The IRS cautions taxpayers that, to the extent they engage in variations of abusive micro-captive transactions that are substantially similar to Notice 2016-66, they must be disclosed. Otherwise, the IRS will impose penalties for the failure to disclose.
Abusive micro-captives have been a threat to tax administration and a concern to the IRS for several years. The transaction has appeared on the IRS "Dirty Dozen" list of tax scams since 2014. In 2016, the Department of the Treasury and IRS issued Notice 2016-66PDF, which identified certain micro-captive transactions as having the potential for tax avoidance and evasion.
The settlement offer followed three U.S. Tax Court decisions confirming that certain micro-captive arrangements are not eligible for federal tax benefits. The terms of the settlement required substantial concession of the income tax benefits claimed by the taxpayer together with appropriate penalties.
Examinations impacting micro-captive insurance transactions of several thousand taxpayers will be opened by these teams in the coming months. Potential civil outcomes can include full disallowance of claimed captive insurance deductions, inclusion of income by the captive entity and imposition of all applicable penalties.
The IRS reminds taxpayers and advisors that disclosure of participation in micro-captive insurance transactions is required with the IRS Office of Tax Shelter Analysis under Notice 2016-66. Failure to properly disclose can result in significant civil penalties. Taxpayers involved in these abusive transactions should immediately consult with independent, competent tax advisors on the proper treatment for past and future tax years to consider best available options.
Herpesviruses are important pathogens in tortoises and turtles, yet little is known about the epidemiology of these viruses. We analyzed herpesviruses detected by PCR in samples from captive chelonians in Europe according to virus strain, host species, year and season in which the animal was tested, and country in which the animal was kept. A total of 4,797 samples submitted to a diagnostic laboratory in Europe between January 2016 and December 2020 were evaluated. Of these, 312 (6.50%) were positive for herpesviruses. The types most commonly found were testudinid herpesvirus (TeHV)1 (143 positive, 45.83%) and TeHV3 (153 positive, 49.04%), but also included TeHV2 (1 positive, 0.32%), TeHV4 (3 positive, 0.96%), Terrapene herpesvirus 1 (7 positive, 2.24%), Trachemys herpesvirus 1 (2 positive, 0.64%), and three previously undescribed herpesviruses (0.96%). Herpesviruses were detected in chelonians in the families Testudinidae, Emydidae, Geoemydidae, and in the suborder Pleurodira. Among the species for which 100 samples or more were available, the highest proportions of positive samples (positivity rates) were found in samples from Horsfield's tortoises (Testudo horsfieldii) (14.96%), and radiated tortoises (Astrochelys radiata) (14.05%). Among tortoises (Testudinidae), viruses were most often detected in the spring, while in emydid turtles (Emydidae) they were most often detected in the summer. A comparison of the positivity rates according to country showed significant differences, with the highest rate in samples from Italy (16.01%). This study indicated possible differences in herpesvirus positivity rates depending on host species, virus strain, year of sampling, season, and country of origin. It provides useful information in further understanding fluctuations in infection rates as well as in helping to guide decision making for herpesvirus diagnostics in chelonian patients. It also provides evidence for the international dispersal of herpesviruses with their hosts through international trade.
A teenager escaping her abusive father is taken captive by a father who is convinced she is his daughter. This was an interesting one. It didn't resonate with me as much on an enjoyment level, but I keep thinking on the dynamics of the lead with her captor. The kind of film I'd like to hear reviewed by those who can speak better to issues of trauma. I see myself mulling this one over for awhile.
1. How to Use Captives for Pandemic Risks. Learn how a captive could help mitigate the financial losses from a pandemic and provide coverages that may be impossible to buy from commercial insurers.
2. How Can a Captive Improve Liquidity From risk financing to intercompany lending, captives can help increase liquidity. We examine short- and long-term liquidity tactics captives can implement to help their parent organizations respond to cash-flow challenges and create more surplus.
3. What Should Captive Owners Consider When Creating A Business Case Captive managers see significant value from their captives. Get stats on what they value most and understand why many are expanding their utilization in response to the transitioning insurance market.
5. What New Lines and Risks are Captives Writing As captives adopt new and increasingly sophisticated technologies, they are writing more risks and lines of business. Learn from captive regulators which emerging lines are seeing the biggest increases.
6. How Can a Captive Create a Profit Center by Writing Third-Party Risks We offer insights into how captive owners and customers each gain advantages when captives are used to write third-party risks, such as extended warranties or affinity risks. 59ce067264