Services Offered

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 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

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