Services Offered

Captive Insurance

  • Formation of captives
  • Conversion of existing captive insurers to new or different entity types (e.g., SPC, PIC)
  • Redomiciling of captive insurers
  • Loss portfolio transfers between captive insurers
  • Review and modification of self-insurance trusts
  • Mergers of self-insurance trusts
  • M&A transactions involving captive insurance programs
  • Analyzing questions of insurance coverage
  • Preparing insurance policies and reinsurance agreements
  • Ongoing general counsel to captive insurers after their formation


Tax

  • Tax treatment of captives and alternative risk transfer arrangements
  • Opinions on federal tax status or expected treatment
  • Guidance regarding tax elections such as Section 953(d) and Section 831(b)
  • Preparation and filing of tax and captive-related tax forms
  • Federal Excise Tax determinations
  • State premium, independent procurement tax, direct procurement tax, and surplus lines analysis
  • FATCA and OECD CRS compliance
  • IRS listed transaction, transaction of interest determination and compliance
  • FinCEN Report 114, also known as the FBAR, formerly known as Treasury Form 90-22.1
  • Section 501(c)(3) tax-exempt status
  • Joint ventures between for-profit and tax-exempt organizations

Business and Corporate

  • Formation of corporations, LLCs and other legal entity structures
  • Operating agreements and operations plans
  • Shareholder and member agreements
  • Changes of ownership and buy-sell agreements

Health Care Law

  • Issues for maintaining Section 501(c)(3) tax-exempt status
  • Contracting between hospitals and physicians
  • All aspects of insurance coverage, including hospital professional liability and physician professional liability