P. Bruce Wright Videos

Bruce Wright

Nationally recognized as an authority in the captive insurance industry, Mr. Wright counsels companies on a wide range of tax and insurance law issues, including formation of commercial offshore privately and publicly held entities.

Contact Info

The Grace Building, 40th Floor
1114 Avenue of the Americas
New York, NY 10036
[email protected]
(212) 389-5054

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Nationally recognized as an authority in the captive insurance industry, Mr. Wright counsels companies on a wide range of tax and insurance law issues, including formation of commercial offshore privately and publicly held entities. He also works with clients on the development of structured financial products such as securitizations, swaps, options, and similar products used as alternatives to conventional risk financing mechanisms such as “rent-a-captives” and “cell companies.”

Representing domestic and foreign-based clients, Mr. Wright advises property and casualty insurance companies, guides the formation of single-parent/group captive insurers, and counsels risk retention groups. With more than 4 decades of experience, he has helped clients successfully navigate an array of complex federal income tax issues such as debt or equity characterization, engaging in U.S. trade or business issues, continuity of interest, passive foreign investment company status, controlled foreign corporation status, limitations on the use of net operating losses, cancellation of indebtedness income, consequences of debt modification, original issue discount, federal excise tax, and state premium tax on premiums paid to foreign investors.

Mr. Wright also holds the Chartered Property Casualty Underwriter (CPCU) designation and speaks regularly at captive industry conferences.


Bruce Wright

Why Is Tax-Deductibility of Captive Premiums Important?

Tax-deductibility of premiums is a key issue for captive insurance companies, and in this video P. Bruce Wright of Eversheds Sutherland (US) LLP discusses how timing is the key factor in this equation.

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Bruce Wright

Tax-Deductibility of Captive Insurance Premiums

P. Bruce Wright of Eversheds Sutherland (US) LLP explains what is required of an insurance contract in order for a captive to deduct its insurance premiums for tax purposes.

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Bruce Wright

"Insurance Risk" as a Tax-Deductibility Requirement

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.

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Bruce Wright

Risk Shifting as a Tax-Deductibility Requirement

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.

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Bruce Wright

Taxation of 831(b) Micro-Captives and IRS Concerns

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.

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Bruce Wright

Taxation of Cell 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.

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