CV-Issue-4-Dale-Fenwick

Reflections from Cayman

I came away from the 2104 Cayman Captive Forum pondering two significant issues. First, the short and long term effect of the Rent-A-Center (RAC), and Securitas Tax Court decisions. Second, the future of offshore captives due to the increased competition from emerging on-shore domiciles. RAC and Securitas: Potential Implications I am not going to regurgitate […]

Dana-Sheridan-ERCpolicy

Best Practices In Insurance Policy Drafting For Enterprise Risk Captive Insurers

Earlier this year the IRS released a list of “dirty dozen” tax scams for the 2015 filing season. The list includes captive insurance transactions that involve “unscrupulous promoters” who form and create an “abusive [captive] structure.” One way that the IRS defined an “abusive structure” was to state that any such structure will involve “poorly […]