CFC Changes Will Impact Group Captives - McDermott Will & Emery

CFC Changes Will Impact Group Captives

Overview


Thomas Jones suggested at the World Captive Forum that the new tax law’s expanded definition of a US shareholder for purposes of controlled foreign corporation (CFC) determination will cause issues for group captives, especially those in Bermuda or the Cayman Islands. “A lot of those [captives] are specially structured but now their special structures don’t work any longer,” Mr. Jones explained.