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What a Captive Insurer Should Know about the 953(d) Tax Election

Bruce Wright
April 22, 2019

A new Captive Thought Leader Video featuring Bruce Wright, partner at Eversheds Sutherland (US) LLP, titled "What Captive Owners Should Know about the 953(d) Tax Election," has recently been added to the video library.

In the video, Mr. Wright discusses section 953(d) of the Internal Revenue Code (IRC). Under section 953(d) of the IRC, non-US-domiciled captive insurers may elect to be taxed as if they were domestic companies for all purposes of the IRC. This means that the captive insurance company is treated as if it was formed in a US state for federal tax purposes.

Mr. Wright also talks about how to make a 953(d) election and explains what happens when a 953(d) election is terminated. According to Mr. Wright, with 953(d) elections, one has to be careful to comply with all of the requirements. He advises that if there is an income tax audit that raises issues that could lead to the 953(d) election being terminated, the captive will need to think about filing protective returns along with other issues.

There is no cost to view the videos, and you will find them in the Captive Thought Leader Videos section of More videos will be added in the future.

(Mr. Wright is pictured above.)

Risk Financing-Withstand IRS Audit

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