Insurance Research Database
GENERAL DISCUSSION & NEWS
GENERAL DISCUSSION AND NEWS
Discussion of news and general issues relating to captive
insurance companies and alternative risk transfer and management
issues. Most new posts will go here unless clearly bound for
Calendar of Upcoming Events
A listing of upcoming events involving captive insurance
companies and alternative risk management, including association
meetings, educational forums, etc. Please send us your meeting
information to add to our list!
STRUCTURING & LICENSING
Formation and Licensing
Discussion of issues relating to the insurance license
application, the issuance of the license, capitalization, etc.
Cell Captives and Rent-A-Captives
Discussion of segregated cell captives and similar arrangements
that are primarily designed for businesses that are too small to
economically justify a captive.
Group Captives and Association Captives
Discussion of large group captives and captives serving
Risk Retention Groups
Discussion of insurance companies formed under the Federal
Liability Risk Retention Act of 1986.
Risks and Policies
Discussion of the insurance risks for businesses and the
policies that can be developed to cover those risks
Discussion of workers compensation insurance, including fronting
arrangements and reinsurance.
Healthcare and Benefits
Discussion of moving employee healthcare insurance and other
employee benefits into a captive or similar arrangement.
Discussion of the use of captive and other alternative risk
transfer strategies for medical malpractice liability. Includes
discussion of tax scams sold to physicians involving medical
malpractice premiums paid to offshore insurance companies.
Tax Issues Generally
Discussion of tax issues relating to captives and other
alternative risk transfer and management issues other than those
listed in one of the forums below.
Federal Risk Shifting and Insurance Contracts
Discussion of the federal tax law requirements for "insurance"
as they relate to the shifting of risks and what constitutes a
valid insurance contract as opposed to an economic hedge.
Federal Risk Distribution
Discussion of the federal tax law requirements of risk
distribution, including what does and does not qualify for the
12+ affiliate safe harbor, and attribution issues.
Federal Excise Taxes on Insurance
Discussion of the federal excise taxes on insurance premiums
paid, including premiums paid to offshore captive insurance
Discussion of the 831(b) election for insurance companies whose
annual net premium income does not exceed $1.2 million per year.
501(c)(15) Exempt Insurance Companies
Discussion of insurance companies qualifying for exempt
treatment under IRC section 501(c)(15) for gross receipts not
exceeding $600,000 per year of which at least half those
receipts are premium income.
State Income Tax and Independently Procured Tax Issues
Discussion of state income tax issues for alternative risk
management transactions and captives, including whether
out-of-state captives are subject to state income tax and
whether a state may assess a premium tax or independently
procured tax to premiums paid to captives.
UTILIZATION OF ASSETS
Discussion of appropriate vs. inappropriate investments for
captive insurance companies, permitted asset rules, and
Discussion of the practice of having the captive loan money back
to an insured or the parent company and the effect of loanbacks
on the tax treatment of the captive arrangement.
DOMICILES - STATES
DOMICILES - OFFSHORE
CAPTIVE SERVICE PROVIDERS
Accountants and Auditors
Listing of accountants and auditors who provide bookkeeping
services and/or have been admitted by an insurance commissioner
to perform audits of captive insurance companies.
Listing of attorneys and law firms that provide services to
captive insurance companies and similar alternative risk
Listing of actuaries who provide actuarial services to captive
Listing of captive insurance managers who have been admitted in
one or more jurisdictions to administrate captives.
Other Service Providers and Consultants
Listing of service providers to captives not otherwise listed
above and consultants to captive insurance companies and
alternative risk transfer structures.