Captive Taxation- Fundamentals of Formation and Redomestication

December 12, 2023

About This Session

The panelists will also explore current tax issues through a review of IRS small captive activity and the implications for large captives, with what might come next. Additionally, this year’s session will outline the fundamentals of captive formation, and its tax consequences, as well as identify the issues to consider when redomesticating a captive from a foreign domicile to Vermont, factoring in tax implications.

What You'll Learn

  • Current tax issues affecting captive insurance companies
  • IRS small captive activity and enforcement trends
  • Tax implications for large captives based on small captive developments
  • Fundamentals of captive formation and structure
  • Tax consequences of establishing a captive
  • Key considerations for captive redomestication
  • Tax implications when moving from foreign domiciles to Vermont
  • What regulatory changes might be coming next
  • Strategic tax planning for captive operations
  • Resources

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    Who Should Watch

    • Captive Owners
    • Prospective Captive Owners
    • Risk Managers
    • Tax professionals and advisors
    • CPAs specializing in captive taxation
    • Legal counsel working with captive formations
    • Captive managers and administrators
    • Companies considering redomestication to Vermont
    • Anyone involved in captive tax compliance and planning

    Speakers

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    Dan Kusaila
    Partner

    Daniel Kusaila is a principal with Crowe Insurance Tax Practice. Daniel has spent his entire career serving property and casualty, captives and life insurance companies in global and multi-state environments. He has significant expertise in the taxation of traditional insurance companies, single parent captives, risk retention groups, association captives, cell companies, risk pools, and reciprocal insurance companies.

    Mr. Kusaila has a deep understanding of all tax aspects of insurance companies, his specific areas of concentration include FATCA, federal and state tax compliance and planning, structuring of off-shore and on-shore captive insurance companies, mergers, acquisitions & reorganizations, private letter rulings, federal excise tax compliance, GAAP financial statement reporting, and Statutory financial statement reporting. He has authored several captive insurance articles for various publications, is a frequent national speaker on topics relating to Federal and State taxation of insurance companies and is an instructor for the International Center for Captive Insurance Education (ICCIE).

    Chaz Lavelle
    Partner

    Charles J. (Chaz) Lavelle was elected to the Captive Review Hall of Fame, and has received VCIA’s “Service to the Captive Industry,” CICA’s “Distinguished Service” and Captive Review’s “Outstanding Contribution” awards. He is a lawyer in the Louisville, Kentucky office of Dentons Bingham Greenebaum LLP. He regularly represents clients before the IRS, and frequently speaks and writes on captive insurance topics. Chaz was outside Tax Counsel for both Humana (brother-sister) and Ocean Drilling (unrelated business) in their captive insurance victories in the U.S. Court of Appeals. Among his civic and charitable activities, he is past Chair of the Kentucky Chamber of Commerce.