Finance, Investments, and Accounting
In this video, P. Bruce Wright of Eversheds Sutherland (US) LLP addresses the special taxation case of micro-captive insurance companies. Section 831(b) of the Internal Revenue Code applies to insurance companies with less than $2.2 million in net premium.
As touched on in the video "Tax-Deductibility of Captive Insurance Premiums," P. Bruce Wright of Eversheds Sutherland (US) LLP expands on what qualifies as a true insurance risk for regulatory and tax-deduction purposes. One of the most important factors is determining if there is an insurable interest.
Linking back to another video, "Tax-Deductibility of Captive Insurance Premiums," P. Bruce Wright of Eversheds Sutherland (US) LLP explains that for an insurance transaction to occur, risk transfer or risk shifting from one party to another and risk distribution are required. Several high-profile cases are also reviewed in this video.
John S. Alberici, of Alberici Corporation, discusses factors that come into play when determining a successful strategy for using multiple captive insurers and discusses how coverage type focus (strategic or tactical) and frequency and severity profiles can help when determining placement of coverages in multiple captives.
P. Bruce Wright of Eversheds Sutherland (US) LLP discusses the evolution of cell captive insurance companies in this video. Mr. Wright touches on tax-deductibility aspects and general taxation aspects as well as some of the complexities surrounding onshore and offshore cell captive taxation.