Captive Insurance Federal Tax Update

Price: $224 OnDemand


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This session will explore recent case law, IRS guidance and legislative proposals affecting existing and newly formed captive insurance companies.   Specifically, the two 2014 Tax Court decisions, Rent-A-Center and Securitas, will be dissected for impact on what constitutes insurance for federal tax purposes.  In addition, the IRS distinction between business risk and insurance risk, as presented in the pending RVI Tax Court case, will be analyzed.   Finally, the session will discuss recent IRS pronouncements and Senate Finance Committee consideration of captives electing to be taxed under IRC Sec. 831(b).

Educational Objectives:
• Learn the latest developments in captive taxation derived from recent court cases, IRS pronouncements and Congressional committee activities.
• Gain insight into emerging trends in federal taxation of captives and their owners.
• Understand how the foregoing may affect pending and future IRS audits of captive and their owners.

Who would benefit most from attending this program? 
Corporate tax managers, captive owners and captive service providers including CPAs, attorneys, insurance managers, actuaries and investment advisers.



Thomas M. Jones is a partner in the law firm of McDermott Will & Emery LLP and is based in the Firm's Chicago office. He focuses his practice on federal and state tax, insurance regulatory and legal matters concerning captive insurance and other alternatives to commercial insurance. He works with multinational corporations, private business, taxable and exempt health care providers, trade associations, joint ventures and enterprises of all sizes.

Tom has extensive transactional experience in all major U.S. and offshore captive insurance jurisdictions, including Arizona, the District of Columbia, Hawaii, South Carolina, the U.S. Virgin Islands and Vermont, as well as Barbados, Bermuda, the British Virgin Islands and the Cayman Islands.

Tom is a member of the bar of the State of Illinois, the American Bar Association, the Chicago Bar Association and the International Fiscal Association. He is a frequent guest speaker at international seminars and conferences, making numerous offshore and onshore presentations on captive insurance and related topics.

In 2008, the Captive Insurance Companies Association (CICA) presented Tom with its Distinguished Service Award. He has served as corporate legal advisor to the New York World Trade Center Captive since 2004. Tom is ranked by Captive Review Magazine as #2 on its 2012 "Power 50" list of the most influential people in the captive industry globally. He is also recognized by Chambers USA and The Legal 500 United States as a leading captive insurance lawyer.



Chaz is a member of the Tax practice group and a member of the firm's Partnership Board. He is primarily engaged in federal tax controversy work, but also has an emphasis on the formation, operation and taxation of captive insurance companies. He has resolved scores of cases with the IRS or in the courts relating to federal income, estate, gift and estate taxes, penalties and interest. Chaz also counsels clients in tax planning, particularly for captive insurance companies and their owners.