8th Annual Legal, Tax and Financial Aspects of Captive Insurance Tax Summit
February 25 & 26, 2008
Westin Casuarina
Las Vegas, NV
This conference will provide you and your company with the tax, legal and regulatory information on structuring, implementing and operating your captive program. Both single parent and group/association captive arrangements, whether onshore or offshore, will be analyzed. Two recent IRS pronouncements will be dissected. In particular, the four captive insurance tax “hot topics” set forth in IRS Notice 2005-49: loan backs, finite risk, cell captive taxation and homogeneity as an element of risk distribution, will be reviewed. The validity of Rev. Rul. 2005-40, limiting insurance tax treatment in single policyholder situations, will be scrutinized. Finally, an in depth case study will demonstrate how a major multi-national company set up a successful risk funding vehicle of itself and its worldwide affiliates.
Various sessions will address the major tax and non-tax advantages, including access to more efficient reinsurance markets, enhanced control over cash flows and investments, as well as promotion of a coordinated focus on proactive risk management and loss control. The parameters of developing a well structured captive insurance program to facilitate acceleration of premium tax deductibility from the time claim payments are made to the time premium expenses are incurred will be discussed. Further, benefits of partial sheltering of investment income using insurance loss reserve deductions will be considered. Finally, certain situations where the profits of the insurance vehicle can be realized in a favorable tax jurisdiction, deferring recognition of taxable income in a higher tax rate jurisdiction, will be explained. ATLAS invites you to learn about these and other current developments in the dynamic captive insurance sphere.
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This two-day seminar is designed to provide Corporate Tax Directors, Controllers, Tax Counsel, CPAs and Attorneys in private practice and other Financial Executives with the vital information they need to help their company or client structure a successful cross-border business merger or acquisition. This is an intermediate to advanced level course, it is recommended that you have taken a introductory course prior to attending.
UP TO 16 CPE/CLE CREDITS AVAILABLE
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