Alliance for Tax, Legal, and Accounting Seminars
&
Structured Finance Institute

Legal, Tax & Financial Aspects of Captive Insurance Companies

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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.

Various sessions will address the major tax and non-tax advantages, including access to more efficient reinsurance markets, enhanced control over cash flows and investments, as well as promotion of a coordinated focus on proactive risk management and loss control.  The parameters of developing a well structured captive insurance program to facilitate acceleration of premium tax deductibility from the time claim payments are made to the time premium expenses are incurred will be discussed.  Further, benefits of partial sheltering of investment income using insurance loss reserve deductions will be considered.  Finally, certain situations where the profits of the insurance vehicle can be realized in a favorable tax jurisdiction, deferring recognition of taxable income in a higher tax rate jurisdiction, will be explained.  ATLAS invites you to learn about these and other current developments in the dynamic captive insurance sphere.

Introductory DVD Available! Click here for more information
 Captives 101 by P. Bruce Wright, Partner, LeBoeuf Lamb Greene & Macrae LLP
Introductory DVD on Basic reasons for forming a captive, and related tax issues.

Conference Materials Order Page - Order Form

Table of Contents

1. Potential Tax Benefits of an Insurance Affiliate
A 32-page handout
  • Tax advantages of a captive insurance company
  • Deductibility of premiums
  • Basic requirements for taxation as insurance
  • Unrelated business theory
  • Brother-sister theory

F. Roy Sedore, Baker McKenzie LLP, New York

2. Review of Business Reasons for Utilizing an Insurance Affiliate
A 35-page handout

  • Captive trends
  • Defining captives
  • Captive domiciles
  • Captive structures
  • Taxation of captives
  • Business reasons for captive formation

Arthur G. Koritzinsky, Marsh USA Inc., New York, NY

3. Onshore Captive Tax and Regulatory Considerations
A 22-page handout

  • Domicile selection factors
  • State law regulatory law – captive as an insurer or reinsurer
  • Onshore vs. offshore federal tax considerations
  • Computation of taxable income
  • Proposed regulations

Tom Jones, McDermott Will & Emery LLP, Chicago, IL

4. Offshore Captive Tax and Regulatory Considerations
A 31-page handout

  • Benefits of utilizing an offshore captive
  • Direct U.S. taxation of offshore captives
  • Election to be taxed as a domestic corporation – IRC section 953(d)
  • Controlled foreign corporations
  • Decontrolled captive
  • Application of the law to cell companies

Roy Sedore, Baker & McKenzie LLP

5. Case Study – Principles of Corporate Finance and Non-Tax Analysis of a Major Multinational Captive
A 25-page handout

  • Overview – Sunrise Senior Living
  • Management services model
  • Community life cycle
  • Management contract economics
  • Insurance captives – formation and purpose

Philip A. Balderston, Sunrise Senior Living, Inc.

6. Employee Benefits as Third Party Risk
A 47-page handout

  • Background
  • Federal income tax
  • State regulatory issues relating to placement
  • ERISA issues
  • Regulatory issues relating to captive insurer
  • Expedited exemption procedure
  • Alternative structures

P. Bruce Wright, Dewey & LeBoeuf LLP, New York, NY

7. Finding Third Party Risk: Internal & External
A 36-page handout

  • To be successful from both an insurance and tax perspective
  • Sharing of risk
  • Risk distribution
  • Theories for success

Charles J. Lavelle, Greenebaum Doll & McDonald PLLC, Louisville, KY

 8. Redomestication of Captives
A 44-page handout
  • Reasons to redomesticate
  • Types of operations
  • Structure alternatives
  • Business considerations
  • Foreign (U.S.) captive
  • Alien (U.S.) captive

P. Bruce Wright, Dewey & LeBoeuf LLP, New York, NY

9. Protecting Confidential Tax Data – Privilege
A 26-page handout

  • Requirements for the three federal privileges
  • Recent developments in privilege
  • Best practices and strategies

Tom Jones, McDermott Will & Emery LLP, Chicago, IL

10. FIN 48 – Accounting for Uncertain Tax Positions
A 10-page handout

  • Scope
  • Initial recognition
  • Measurement
  • Interest and penalties
  • Tax planning strategies

Tom Jones, McDermott Will & Emery LLP, Chicago, IL
Gary Bowers, Johnson Lambert, Raleigh, NC

11. State Taxation of Captives
An 18-page handout

  • Background
  • Methods of state taxation
  • Constitutional limits on states’ power to tax outside borders
  • Key decisions
  • Take aways

Holly K. Hemphill, McDermott Will & Emery LLP, Washington, DC

12. Federal Taxation and Legal Aspects of “Cell” Companies and Rent-a-Captives
A 30-page handout

  • Cell company structure
  • Offshore cell captive world
  • Onshore cell captive
  • General and segregated accounts
  • Key U.S. tax issues

Tom Jones, McDermott Will & Emery LLP, Chicago, IL

13. Companies Repatriation of Captive Profits
An 18-page handout

  • Dividends to U.S. owners
  • Loan Backs to U.S./foreign persons
  • Pledge of captive assets/shares by U.S. parent
  • Captive guaranty of U.S. parent debt
  • Reduction of future premiums

Tom Jones, McDermott Will & Emery LLP, Chicago, IL

14. Basics of Captive Tax Compliance
A 16-page handout

  • Offshore captive filings
  • Form 1120F, 5471, 720
  • Tax rates on insurance for excise taxes
  • 953 (d) filing and test
  • Onshore captive filings

Gary Bowers, Johnson Lambert, Raleigh, NC

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Please send me the Course Materials AND the Introductory DVD - $370 (295 material + 75 dvd)

Please send me the course materials ONLY - $295

Please send me the Captives DVD ONLY - $125

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