Michael Domanski is a partner and leader of the Insurance Tax Practice Group. He is a seasoned attorney with a practice dedicated to captive insurance with a focus on international transactions. With more than 25 years of international and domestic captive insurance experience, he represents individuals, tax-exempt organizations and private/public companies involved in US inbound and outbound transactions and multi-state arrangements.
- Advises tax-exempt and for-profit entities in the organization and maintenance of self-insurance programs, risk purchasing groups, segregated portfolios/cells, series LLCs, mutual insurers/reciprocals, stock captive insurance companies and risk retention groups
- Counsels clients in the development of structures that are tax-efficient from a U.S. federal and state perspective in the context of cross-border joint ventures, mergers and acquisitions, financings, and reorganizations
- Represents clients in connection with controversies involving the Internal Revenue Service and state agencies
- Provides recommendations regarding captive domiciles, ownership structure, insurance policy provisions, funding approaches, profit repatriation and inter-company agreements from a legal and tax perspective
- Analyzes U.S. federal income, federal excise tax and state procurement tax implications of international and captive insurance transactions, including matters related to controlled foreign corporations/Subpart F, passive foreign investment companies, unrelated business income tax, U.S. withholding tax, premium tax deductibility, entity classification, and taxation of premium payments to captive insurance companies
- Provides advice regarding the preparation of federal tax and information returns impacted by international and captive insurance arrangements, including IRS Forms 8865, 8858, 8833, 8832, 5472, 5471, 926, 720, 1120-PC, 1120-F, W-8/W-9 (FATCA) and FinCEN Forms (114/FBAR, Corporate Transparency Act)