IRS Decks Warranty Premium Tax Shelters
Dealers using offshore reinsurance-company accounts to “shelter” their warranty-contract and credit insurance income have been struck a blow by the Internal Revenue Service.
Under a notice published in the November 4, 2002 Internal Revenue Bulletin, the IRS has challenged the position that so-called producer-owned reinsurance companies (PORCs) incorporated abroad are tax-exempt if premiums do not exceed $350,000 a year.
Most PORC accounts are based on tax-free islands like Grand Cayman or Turcks and Caicos in the Caribbean Sea. Dealers using these accounts are on the increase, according to Robert C. Zwiers, dealer taxation executive for the Crowe Chizek CPA firm in Grand Rapids, MI, who says the impact on them could be “severe.”
“For federal income tax purposes,” says the IRS Bulletin, #2002-70, “an insurance company is a company whose primary and predominant business activity is the issuing of insurance or annuity contracts or the reinsuring of risks underwritten by insurance companies.”
The Bulletin declares that exceptions for foreign corporations are only available to those engaged in the insurance business.
A number of warranty and credit life and health providers have advised dealer customers to ‘park’ premiums in PORC accounts maintained offshore. Zwiers, a former IRS officer specializing in dealer taxations, voiced surprise that the IRS seems to be reversing a policy of permitting such accounts as tax-free funds.
IRS officials who prepared the tax-shelter bulletin are John Glover, Theodore Setzer and Sheila Ramaswamy, located in the agency’s Washington headquarters.
More F&I

AI: Facilitator, Not Fixer, in F&I
The dealerships that thrive in the years ahead will be those that embrace technology while continuing to invest in the people who make customer interactions count.
Read More →
Modern Technology Objection Handling
In this video, Trent White shares how to confidently handle technology-based objections by helping customers understand the value of protection, even with modern vehicle technology.
Read More →
Consistency at Scale: Driving F&I Performance
With 75 rooftops across the Sunshine State, Morgan Auto Group has proven to Floridians that it knows a thing or two about driving performance in a competitive market. But it didn’t start at the top.
Read More →
Gitty Up on GAP
The foundational finance-and-insurance product hasn’t kept up with the latest conditions for auto dealers. Is the time ripe?
Read More →
How AI-Powered Coaching Is Transforming F&I Performance
See how AI-powered coaching can turn F&I customer conversations into actionable insights that support compliance, performance and profitability
Read More →
Sell Value, Build Trust
In this video, Trent White explains why selling on value, not fear, builds lasting customer trust, reduces cancellations, and drives long-term success.
Read More →
F&I Sales Give Dealers First-Half Lift
Product business shored up total profits to avoid an overall revenue tanking as product penetrations held steady, StoneEagle reported.
Read More →
Targeted Training Drives Results
Today’s technology, instead of threatening F&I managers, can actually make them better, according to an industry veteran who’s watched market setbacks roil the unprepared.
Read More →
Double the Change, Double the Chance
When an F&I manager gets a customer refusal, it’s a wise move to tweak more than one thing in the product offering.
Read More →
Just Do It
F&I managers need training, but instead of resisting application or expecting perfection, they should improve by simply acting on what they learn.
Read More →