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Course Details

Modern Captive Structures - Taxation and Accounting

Webinar: ID# 1015118
Recorded CD
Qty:
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 will provide 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.

Agenda

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
  • Income Taxes - State
  • Excise Taxes
About The Presenters

Philip J. Tortorich
  • Head of Katten Muchin Rosenman LLP'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 his 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
Jeffrey J. Webb
  • Senior manager in the Financial Services practice of Deloitte Tax LLP
  • Ten years of experience working with financial services companies, primarily focusing on the insurance and banking industries
  • Significant amount experience assisting commercial and consumer insurance companies and banks with their financial reporting for income tax calculations, focusing on the tax and accounting technical, as well as the process aspects of these calculations
  • Assists companies with establishing, maintaining, gaining efficiencies and integrating multiple structures with their closely held insurance platforms
  • Supports companies with the implementation of provision and tax return software solutions which includes the design, testing and go live support, as the financial services subject matter expert
  • Experienced in transaction based advisory: buy and sell side, 338(h)(10) transactions, carve out accounting and modeling; and other tax consulting: taxpayer consolidation issues (life / non-life, dual consolidating losses), tax profile modeling, controversy, and deficiency remediation with a focus on tax department roles, responsibilities and tax data sensitization
  • Licensed certified public accountant in the state of New York, a speaker at industry conferences and a member of the AICPA, NYSSCPA, Wall Street Tax Association and SIFM
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Modern Captive Structures - Taxation and Accounting
Available on CD format
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