Captive Insurance Tax Forum - Fall 2019 - McDermott Will & Emery

Captive Insurance Tax Forum – Fall 2019


A two-day conference with group live instruction featuring a comprehensive update on the legal, tax, and financial aspects of the captive insurance industry today.

Capacity is limited. Registrations will be accepted on a first-come, first-served basis. Fee includes continental breakfasts, lunches, refreshment breaks, cocktail reception and course materials in electronic format.


  • Review of Business Reasons for Utilizing an Insurance Affiliate
  • Evolution of Federal Taxation of Captives
  • Potential Tax Benefits of an Insurance Affiliate
  • Onshore Captive Tax and Regulatory Considerations
  • Offshore Captive Tax and Regulatory Considerations
  • Making a Foreign Insurer a Domestic Taxpayer
  • Risk Distribution: Siblings or Strangers or Exposure Units?
  • Accounting for Income Taxes
  • Employee Benefits as Third Party Risk
  • Federal Excise Tax Developments
  • Pools and Other Third Party Risks – What, Where and Why
  • ILS (Insurance-Linked Securities)/“Cat” (Catastrophe) Bond Market
  • Redomiciling of Captive Arrangements
  • Update on Proposed Regulations Relating to Passive Foreign Investment Companies
  • Audience Questions plus Discussion of Recent Captive Rulings and Cases
  • Procedural Overview of the IRS Audit Process
  • State Taxation of Captives
  • Repatriation of Captive Profits
  • Sec 831(b) Election and Consequences
  • Overview of Cell, Series and Rent-a-Captives
  • Basics of Captive Tax Compliance
  • Tax Aspects of Captives Owned by Exempt Organizations

CLE credit is pending in California, Georgia, Nebraska, New York and Texas. This program is transitional which is appropriate for newly admitted attorneys. A uniform Certificate of Attendance will be made available to participants requesting CLE credit in all other jurisdictions.

CPE credit is also pending.

Registration Information


October 28, 2019
7:30 am – 5:30 pm (MST)
5:45 pm – 6:45 pm (MST)
Cocktail Reception

October 29, 2019
7:30 am – 3:30 pm (MST)


2325 E Camelback Rd,
Suite 120
Phoenix, Arizona 85016

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Kristen E. Hazel

Partner & Deputy General Counsel | Chicago

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