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831(b) ground rules emerge post Syzygy
Syzygy Insurance v Commissioner may paint a negative picture of the industry, but also provides some helpful guidance on how to structure small captives, says David Kirkup, chief operating officer at Captive Alternatives.
Captives industry cannot expect to be found, it must engage with students
The demand for insurance talent is growing, which is especially true for the captive insurance industry. With baby- boomers retiring, generation X aging and millennials switching off at the mention of insurance - , where is the talent going to come from? Kathleen O’Neil Larkin, attorney and instructor at Missouri State University, says the gap between industry and academia must be bridged.
Microcaptives help facilitate ERM programmes for SMEs
An enterprise risk management micro-captive programme may not be as robust as a mega-company's ERM programme, but many of the same benefits may be achieved. Ryan Ralston, director of risk management at Elevate Captives, has the details.
Pilot v Commissioner: key questions raised and left unanswered
Just 10 days before the scheduled trial in the US Tax Court, the taxpayers conceded the remaining issues in Pilot Series of Fortress Insurance et al v Commissioner. The pretrial pleadings highlighted many of the key questions that remain open in litigation over the tax treatment of captive insurance transactions. Those questions—and the parties’ efforts to answer them—provide a roadmap of what to expect as additional cases move toward trial. Jenny Johnson Ware, founding partner of tax litigation boutique Johnson Moore, analyses those key questions and what we can learn from them—despite the fact that the Tax Court will not be providing any answers.
The path to good corporate governance
The failure of a captive can often be traced to a breakdown in quality corporate governance. Ben Whitehouse, senior counsel at Butler Snow, outlines the important attributes of good captive governance.
Domiciles: business friendly or tax focused? How to prepare your captive
Could high-profile settlements with the State of Washington lead to more captive domiciles following a similar path? Or will they adopt a more pro-business stance, like North Carolina? Pete Kranz, executive managing director and captive practice leader of Beecher Carlson, provides some key considerations on where to domicile a captive.
A&H solutions for optimising captive risk assumption
As the lines between P&C and A&H coverages continue to blur, captives are gaining increased crossover relevance and are being used in more innovative ways. Phillip Giles, vice president, sales & marketing, accident & health, at QBE North America, has the details.
Lloyd’s Lab: shaping the future for complex, hard-to-place risks
On May 6 the second cohort of Lloyd’s Lab kicked off in the venerable Lloyd’s building on Lime Street—the heart of the London Market. Marcus Schmalbach, CEO and founder of Ryskex, provides a glimpse behind the scenes from the eyes of a participant.
Risk pools: guesswork not allowed
The outcome of Syzygy v Commissioner marks another IRS victory against 831(b) captives. What went wrong this time? Matthew Queen, general counsel & chief compliance officer, Venture Captive Management, has the details.
BEPS and substance requirements: Hugh’s views
Guernsey has satisfied the much-debated OECD BEPS substance requirements for captives operating there. Industry veteran and retired principal of Towers Watson, Hugh Rosenbaum, shares his views.
