Modern Captive Structures - Taxation And Accounting

Webinar: ID# 1014351
Recorded CD
About This Course:
In 2002, the Internal Revenue Service issued a number of Revenue Rulings and other guidance that clarified several major aspects of its position on the tax outcome of captive insurance planning (though many issues still remain).

Combining this with a push in the industry to lower the overall cost of setting up and administering the program, captives have recently become a new planning tool for mid-sized closely held businesses.

Given the influx of new captives, it is important you understand how the captive insurance company will be treated and how it interacts with the operating businesses.

This webinar provides an overview of the modern captive insurance structures being utilized and will discuss the tax characteristics of the insurance company and how both the operating company and the insurance company should be treated from an accounting perspective. We will review 831(b) elections that can be applicable to smaller captives and we will review the regulatory requirements that are common to most domiciles.


Modern Captive Structures
  • Pure Captives – Subsidiary
  • Purchase Captives – Brother-Sister
  • Sponsored Captives – Cell Structures
  • Sponsored Captives – Series Structures
Accounting Issues
  • GAAP vs. Statutory Accounting
  • Accrual vs. Cash Accounting
  • Domicile Regulatory Matters
Tax Issues
  • Income Taxes - Federal
  • Risk Shifting
  • Risk Distribution
  • Common Notions of Insurance
  • Operational Matters
  • Available Tax Elections
  • Guidance on Cell/Series Structures
  • Income Taxes - State
  • Excise Taxes/ul>Closing

Philip J. Tortorich
  • Head of the firm’s captive insurance practice
  • Advises wealthy individuals and closely held companies on the creation and management of captive insurance programs, as well as tax and estate planning matters
  • Has worked in the captive insurance space for more than a decade and is one of only a few attorneys who handle both the income tax and estate and gift tax aspects of captive insurance programs for closely held middle market businesses
  • Much of Phil’s work involves consulting with clients on the tax efficient structuring of corporate entities including C corporations, S corporations, limited liability companies, limited partnerships and hybrid-type entities
  • Assists clients in designing onshore and offshore trusts that minimize their exposure to gift taxation and in structuring family investment companies that fit their specific circumstances and trust and estate plans
  • J.D. degree, Loyola University Chicago School of Law
  • B.A. degree, Loyola University Chicago
Modern Captive Structures - Taxation And Accounting
Available on CD format
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