Personal taxes, cost of insurer equity capital, and the case of offshore hedge fund reinsurers
研究了美国个人税收对保险公司股权资本税收成本的影响，以及这种成本如何随时间、税制和资产组合变化，并分析了个人税收如何激励离岸对冲基金再保险公司的形成。
Abstract Insurer investment returns are taxed in the United States at the corporate level and at the personal level when they are distributed to shareholders. This paper examines the implications of personal taxes for the tax cost on insurers equity capital and how these tax costs have varied over time under different tax regimes and with different asset portfolios. The paper also discusses how personal taxes provide tax incentives to form offshore hedge fund reinsurers, which provide an interesting case study illustrating the relevance of personal taxes. Finally, the paper discusses the tax treatment of alternative capital arrangements, such as collateralized reinsurance and sidecars.