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Many parties get it in connection with transactions to reduce uncertainty, make investments more appealing, provide cost-effective risk mitigation, etc. Some issues regarding the tax treatment of insurance are clear, while others are evolving. The latter category includes whether partnerships can claim deductions for paying premiums. This article by Partner Hale Sheppard describes two main types of insurance, earlier administrative guidance about deductibility, criticism of such guidance, and a new Tax Court ruling in 2026. The materials on the Eversheds Sutherland website are for general information purposes only and do not constitute legal advice. While reasonable care is taken to ensure accuracy, the materials may not reflect the most current legal developments. Eversheds Sutherland disclaims liability for actions taken based on the materials. Always consult a qualified lawyer for specific legal matters. To view the full disclaimer, see our Terms and Conditions or Disclaimer section in the footer. Services Tax Tax Controversy and Litigation Key contacts Hale E. 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Eversheds Sutherland Entities are constituted and regulated in accordance with relevant local regulatory and legal requirements. The use of the name Eversheds Sutherland, is for description purposes only and does not imply that the member firms or their controlled, managed or affiliated entities are in a partnership or are part of a global entity. The responsibility for the provision of services to the client is defined in the terms of engagement between the instructed firm and the client. For information on Konexo please also see the Legal Notices page of this website ATTORNEY ADVERTISING - Prior results do not guarantee a similar outcome. Unless otherwise indicated, attorneys at Eversheds Sutherland (US) LLP are not certified by the Texas Board of Legal Specialization.

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Tax Court Rejects Deductibility of Partnership’s Tax Insurance Premiums

May 18, 2026

United States

TAX ANALYSTS

Tax result insurance, once a novel concept, is now commonplace. Many parties get it in connection with transactions to reduce uncertainty, make investments more appealing, provide cost-effective risk mitigation, etc. Some issues regarding the tax treatment of insurance are clear, while others are evolving. The latter category includes whether partnerships can claim deductions for paying premiums. This article by Partner Hale Sheppard describes two main types of insurance, earlier administrative guidance about deductibility, criticism of such guidance, and a new Tax Court ruling in 2026.

The materials on the Eversheds Sutherland website are for general information purposes only and do not constitute legal advice. While reasonable care is taken to ensure accuracy, the materials may not reflect the most current legal developments. Eversheds Sutherland disclaims liability for actions taken based on the materials. Always consult a qualified lawyer for specific legal matters. To view the full disclaimer, see our Terms and Conditions or Disclaimer section in the footer.

Hale E. Sheppard

Partner

Atlanta, United States

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Eversheds Sutherland is the name and brand under which the members of Eversheds Sutherland Limited (Eversheds Sutherland (International) LLP and Eversheds Sutherland (US) LLP) and their respective controlled, managed or affiliated firms and the members of Eversheds Sutherland (Europe) Limited and Eversheds Sutherland (Africa) Limited (each an "Eversheds Sutherland Entity" and together the "Eversheds Sutherland Entities") provide legal or other services to clients around the world. Eversheds Sutherland Entities are constituted and regulated in accordance with relevant local regulatory and legal requirements. The use of the name Eversheds Sutherland, is for description purposes only and does not imply that the member firms or their controlled, managed or affiliated entities are in a partnership or are part of a global entity. The responsibility for the provision of services to the client is defined in the terms of engagement between the instructed firm and the client. For information on Konexo please also see the Legal Notices page of this website
ATTORNEY ADVERTISING - Prior results do not guarantee a similar outcome.
Unless otherwise indicated, attorneys at Eversheds Sutherland (US) LLP are not certified by the Texas Board of Legal Specialization.

Tax Court Rejects Deductibility of Partnership’s Tax Insurance Premiums

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