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Commissioner, affirming the Tax Court’s ruling in favor of the IRS. 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 Captives Insurance Taxation Key contacts Saren Goldner Partner New York, United States P. 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Fifth Circuit Holds for IRS in Swift Captive Insurance Case

July 23, 2025

United States

Captive.com

Eversheds Sutherland attorneys Saren Goldner and Bruce Wright are featured in this Captive.com article discussing the Fifth Circuit’s decision in Swift v. Commissioner, affirming the Tax Court’s ruling in favor of the IRS.

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.

Saren Goldner

Partner

New York, United States

P. Bruce Wright

Of Counsel

New York, United States

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Spanish employment law training
virtual | June 09, 2026
UK employment law training
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Introduction to Swiss employment law

Tabs Label

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legal updates

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podcasts and webcasts

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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.

Fifth Circuit Holds for IRS in Swift Captive Insurance Case

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