×

Web Events

Micro-Captive Transactions: What's Next and How Can You Prepare

    Select Date & Time:
  • $59.00-$69.00
    Micro-Captive Transactions: What's Next and How Can You Prepare 01:00 pm - 02:00 pm ET Product #: WC1469405
    Add to Calendar 08/24/2017 13:00:00 08/24/2017 14:00:00 America/New_York AICPA Webcast: Micro-Captive Transactions: What's Next and How Can You Prepare
    Learn how to navigate the IRS examinations and the new reportable transaction disclosure requirements.
    Register at http://www.aicpastore.com/Tax/PRDOVR~PC-WC1469405/PC-WC1469405.jsp AICPA noreply@aicpastore.com false MM/DD/YYYY AICPA WebEvent aiEQlNoFjzFNtMgVwmLn20911
    AICPA Member: $59.00
    Non-Member: $69.00

For the past several years, the Internal Revenue Service (IRS) has been focusing on small captive insurance companies. Currently, the IRS is committing significant resources to examining insureds, captive insurance companies, and captive managers. There are also numerous cases docketed in the U.S. Tax Court. Furthermore, on November 1, 2016, the IRS issued Notice 2016-66 identifying certain transactions relating to small captive insurance companies as a "transaction of interest." The new designation triggers disclosure requirements with significant penalties for non-compliance. Finally, the IRS Large Business & International Division has created a coordinated effort to examine captive insurance issues in its recently-announced "campaign" program. In this webcast, learn how to navigate the IRS examinations and the new reportable transaction disclosure requirements.

Learning Objectives

Learning outcomes include:

  • Understanding the tax implications of establishing a small captive insurance company under section 831(b) of the Internal Revenue Code
  • Understanding of the IRS's concerns with small captive insurance companies
  • Understanding the tools used by the IRS to examine insureds, captives, and captive managers
  • Understanding of the IRS disclosure regime for transactions of interest (TOI) under Internal Revenue Code and Treasury Regulations for transaction participants and advisors
  • Understanding of the penalties for failure to disclose a TOI under Internal Revenue Code and Treasury Regulations for transaction participants and advisors

Who Should Attend This Event?

CPAs representing captive insurers and their constituents

Important Information on Your CPE Credit

Discounts

PFP/TAX section members and PFS credential holders receive a 20% discount:

When you log into this website with your AICPA member account, the section discount will be automatically applied during checkout. Section discounts cannot be combined with any other offer. Should you have any questions or encounter any issues, please contact the AICPA Service Center at 888-777-7077 or service@aicpa.org.

Private Companies Practice Section (PCPS) members save an additional 20%:

PCPS members: Login here to obtain the discount code to enter for this event. Not sure your firm is a member? Send an email and we'll get right back to you! Or, learn more about PCPS membership! Should you have any questions or encounter any issues, please contact the AICPA Service Center at 888-777-7077 or service@aicpa.org.

Group Viewing Option

Gather the team together and attend this webcast as a group. Each attendee will earn CPE Credit. Enter the number of attendees in the quantity box above.

Number of Attendees Non-Member Member

1 - 4

$69 $59

5 - 9

$65 $55

10 - 20

$59 $49

21 +

$55 $45

Your order confirmation will include an instruction document for group viewing and earning CPE credit (please review prior to the start of the event) and information on how to access the webcast.

Included in:Annual Webcast Pass

Get year-round unrestricted access to this and more than 500 webcasts featuring top experts, regulators and agency representatives discussing topics of importance to you. Learn more...


Speaker Bio

Rachel L. Partain

Ms. Partain is a Member in Caplin & Drysdale's New York City office, where her practice focuses on representing high-net-worth individuals (HNWIs), corporations, and TEFRA and other partnerships in complex federal and state tax controversy and litigation matters.

She provides skilled counsel to clients involved in examinations, appeals, tax and bankruptcy litigation, collections, compliance reviews, and internal investigations. Moreover, Mr. Partain partners with clients to develop policies and procedures that help reduce their risks and enhance their business operations. Her experience includes representing captive insurance arrangements involving income tax and federal excise tax (FET) issues.

Christopher S. Rizek

Christopher S. Rizek, J.D., LL.M., is a Member in Caplin & Drysdale's Washington, D.C., office. He also serves as General Counsel to the firm. In 2014, he was listed in the elite "Leading Lawyer" list for Tax Controversy by The Legal 500. Mr. Rizek represents taxpayers in all types of federal civil and criminal tax controversy matters. He also guides clients through IRS audits, prepares administrative claims and protests of IRS actions, and litigates tax and tax-related cases in U.S. district and appellate courts, the U.S. Court of Federal Claims, and the U.S. Tax Court. In recent years, he has represented numerous financial and professional firms in connection with IRS examinations of tax shelters and related compliance and professional ethics issues.

Mark D. Allison, J.D., LL.M.

Mark D. Allison, J.D., LL.M., is a Member in Caplin & Drysdale's New York office. Mr. Allison's practice involves complex federal, state, and cross-border tax controversy and litigation matters; related civil, criminal, and regulatory proceedings; and internal investigations. He represents multinational corporations, financial institutions, and high net worth individuals and professional athletes in proceedings before the Internal Revenue Service, the U.S. Department of Justice, the U.S. Attorneys' Office, and other government regulators, with substantial industry experience in financial services, healthcare, utilities and infrastructure.

System Requirements