Lessons from the Avrahami Case

Wednesday, September 6, 2017

Reserve Your Seat

Recording date:
Wednesday, September 6, 2017

Panelist Information:
Chaz Lavelle, Michael Domanski and Brady Young

1 hour 6 minutes

The captive industry has been eagerly awaiting the outcome of Avrahami vs Commissioner, the first 831(b) captive insurance case litigated in US Tax Court. After a ruling in favor of the IRS, what does this mean for the captive industry? While this case directly impacts micro captives bringing some much needed clarity to the 831(b) election, the ruling also has implications for 831(a) captives and non-profit owned captives. In this webinar we take a broad look at the implications for the captive industry as a whole. Specific topics covered will include:

  • Facts of the case.
  • IRS position and basis of court opinion.
  • Implications for captives taking an 831(b) election.
  • Broader implications
    • Risk distribution: exposure units versus legal entities
    • Operational considerations for captives
    • Loan backs
    • Insurance risk versus business risk.
  • Implications for captives owned by non-profits/tax-exempt organizations
  • Implications for 831(a) captives.

This webinar is suitable for all existing captive owners and any prospective captive owners whether they take an 831(b) election or not.

Charles (Chaz) Lavelle, Partner, Bingham Greenebaum Doll LLP. Chaz is listed in Captive Review’s Power 50 and ERC Pioneer 20, and is a frequent speaker and writer on captive insurance topics. Chaz was outside Tax Counsel for both Humana and Ocean Drilling in their captive insurance victories in the U.S. Court of Appeals. Among his civic and charitable roles, he was past Chairman of the Kentucky Chamber of Commerce.

Michael Domanski, Partner and Leader, Insurance Tax Practice, Honigman Miller Schwartz and Cohn LLP. Michael has over fifteen years’ experience in international tax matters and alternative risk financing mechanisms. He advises tax-exempt and for-entities in the organization and maintenance of captive insurance companies, self-insurance programs, risk purchasing groups, rent-a-captives, and risk retention groups. His practice also includes analysis of US U.S. federal income and excise tax implications of international and captive insurance transactions.

Brady Young, President and CEO, Strategic Risk Solutions will moderate the webinar.

Contact info@strategicrisks.com for a password to view this recording

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