122, 2:05 PM. Ha “tax implications for captives" | Search | Linkedin & twork Jobs Posts) People Jobs Groups Companies Schools. Courses Messaging Notfcations Events ) “Services Posts ®@ Lance Wallach 31+ . 3mo+® Currently, there isa tax provision that allows ‘micro-capive insurance companies ~ «eated to provide insurance to small companies that create them ~ to earn premiums tax free. Ultimately, this was intended to provide more affordable insurance coverage to policyholders. When the insurance company is well diversified, these have not been an Unfortunately some taxpayers have abused the system to benefit themselves without providing real or realistic insurance polices, or have provided minimal insurance for ‘exorbitant prices. These cases of concem around micro-captive insurance companies that are set up with fully deductible premiums and no tax payments, and with litle to ‘no ability forthe IRS to review them, has provided reasons for policy change. Therefore, Lnder President Biden's green book, there are several proposed provisions to make those arrangements much more costly forthe captive insurance companies. Here is a ‘summary of the proposed guidelines and impacts: Proposal to establish an untaxed income account (UIA) regime. This applies to any ‘captive insurance companies that receive 20% of more of their premiums from any one policyholder or a related group of policy holders. Impact to captive insurance companies It allows the company not to pay taxon these premiums, and dividends or loans made tothe insured parties would be treated as a ‘deemed distroution from the UIA and taxed ata high rate, “At this early stage, coupled with recent IRS activity, we're watching to see what will take shape to stand before Congress. But we fully expect new tax requirements in some form ‘0 eliminate the ability of those captives abusing the tax-free provision for smal insurance companies” says Lance Wallach, an expert witnes in captive insurance lawsuits whose side has never lot a cas. Ifyou own or participate in a “micro-captve” insurance company, speak to your captive ‘manager about their reinsurance and ceding percentages, and to your captive manager ‘and captive tax retum preparer to discuss potential implications of these proposals insurance Scaptiveinsurance #captiveinsuranceaudit#taxaudit #expertwitness 02 2conments share Dike Oeomment Share Asend ic Inregro LLP follow «+ 5iolowes ‘insurance #insuranceindustry #captiveinsurance #captves #ra #insuranceregulators #insurancecouncils#insuranceassociations #irdai india #kenya #uganda #tanzania rwanda #burundi Pe AY . Pa -ntpsthwwlinkedin.comsearchiresulsallheroEntiyKey=urn%43Al%3Aautocomplete%:3A-17624574508keywords=tax implications for captives... 18122, 2:05 PM. “tax implications for captives" | Search | Linkedin ike QDeomment Share A send Miguel Meléndez «3+ + Follow +++ Listen Follow. Lead ‘© ‘few thoughts from tonight's City Council meeting 1) the statements and impacts around 485-a ae overstated in my opinion | ..see more O@i8 6 comments Stike QDeomment share send See all post results People Bruce Wright- 2nd Connect Q rere sie suretns sur ) New York NY Current nscance and TaxFartner at Eversheds Sutherland _ames Bulkowskiand Andrew Chrstieare shared connections Bill A + 3rd Comessage ) Exec. Director of Tax and Payroll - Comell University \ 7 Ithaca, NY Current: Eee Director of Taxand Payot - Corel Univesity at Cornell Univesity e Linkedin Member Summary: igen USaximplications of non US retement. See all people results More posts Mithril International + Follow + 453 followers aw ‘The owner-manager trying to raise funds inthe US for a non-US business must reduce ‘the risk oftheir investment oer. Especaly if they want to raise funding of US2OM or ‘more from US and international investors. Investors are going to look atthe ..see more MITHRIL njpsthwwlinkedin.comsearchiresulsallheroEntiyKey=urn%43Al%3Aautocomplete%k3A-17624574508keywords=tax implications for captives... 218‘913722, 2:05 Pt “tax implications for captives" | Search | Linkedin Intemational Fundraising - Intemational Private Investment Funds + Fiduciary Duty Part I Mit Iernaona on inked «8 min 08 1 share DS Like © Comment Share send ashutosh kumar 3+ +Follow + Chief Manager aw ‘The net zero transition will transform business and industry But the pace is slow. ‘The urgency fora global leaders to implement net zero transition ashutosh kumar on Linkedin + 4 min 08 oo Aiite © comment share Assen Lance Wallach « 3+ “ 3mo+® Lance Wallach, National Society of Accountants Speaker ofthe Vear is featured at more ‘than 20 conventions annually, including the annual national conventions of .se2 more oO 1 share Like ©Deomment Share send David Wilson + 3rd + Follow + retired at 14ddiison wwe® _npstiewwiokedin,consearchiresulsall?heroFntyKey=un%43Al%3Aaulocomplete%e3-t7624574508Keywords=tax implications for captives... 316iar, 2.05 PI Ha “tax implications for captives" | Search | Linkedin Pp SLAVERY, ALL IT ENTAILS: THE PRESENT IMPLICATIONS! o1 like QDeomment Share A send Sandra Nolan + 3ici+ +follow » Monaging Director, Connect Speakers Bureau ‘RicharaHames #ConnectSpeakersBureau #Fowershift \ APR P hee = ipnias a gee c es aipyae Powershift The path to salvation nobody will tak about Sandra Nolan on Une « 30 mined 6: Alike QDeomment share A send -~ hitps:lwwu_ linkedin comsearchiesulisfall?heroEntiyKey=un%e3Al %-3Aautocomplete%3A-17624574508Keywords=tax implications for captives... 4/5122, 2:05 PM. Ha ‘np: tiewwiokedin.consearchiresulsall?heroFnyKey=un%43A] %3Aaulocomplete%e3A-17624574508keywords=tax implications for captives, “tax implications for captives" | Search | Linkedin ft = It's time for the transcript version ofthis week's business conversation with Lesley Hensell Demond caret Making conversations about selling on Amazon count with Lesley Hensel Making Conversations Cunt id an inkeln «25min rad Slike © comment Share Ascend Mercer wee Meer 604K folowers imo-@ ‘As concems about recession rises to the top of leadership agendas it's no surprise for employers to continue to do their best to hold anto profits, and increase liquidity while navigating a tight labor market. We discuss how inflation may trigger ..see more en i Poor Did you know Pe tae Urs) Pier ae oe eee a eae eet i Pees Pear eed Increased scrutiny is ralsing the bar on benefits governance 55122, 2:05 PM. “tax implications for captives" | Search | Linkedin = ° a ft fa sere Wyn Je NSegieis D Like Qeomment Share send See all post results > Fiter by author, date posted, and more ‘Are these results helpful? © @ Your feedback helps us improve search resuits Ad CCHARUL stay informed on indus nes and trends Be 4 CCHARUL, keep up with the latest insights ‘rom Global Al Summit, pst linkedin.comsearchiresulsallheroEntiyKey=urn%3Al%3Aautocomplete%:3A-17624574508keywords=tax implications for captives... 61