8th Annual Legal, Tax and Financial Aspects of Captive Insurance Tax Summit
October 30 & 31, 2008
The Westin Hotel Washington D.C. City Center
Washington D.C.
This conference will provide you and your company with the tax, legal and regulatory information on structuring, implementing and operating your captive program. Both single parent and group/association captive arrangements, whether onshore or offshore, will be analyzed. Two recent IRS pronouncements will be dissected. In particular, the four captive insurance tax “hot topics” set forth in IRS Notice 2005-49: loan backs, finite risk, cell captive taxation and homogeneity as an element of risk distribution, will be reviewed. The validity of Rev. Rul. 2005-40, limiting insurance tax treatment in single policyholder situations, will be scrutinized. Finally, an in depth case study will demonstrate how a major multi-national company set up a successful risk funding vehicle of itself and its worldwide affiliates.