Captivating Thinking

Allianz released its Top 10 Global Business Risks for 2017 (CLICK HERE), and it highlights an ongoing and powerful shift in the threats companies face.  Many of these threats are emerging (new and developing more fully), imminent (due to active perpetrators), AND not adequately addressed by the commercial insurance market (because coverage is difficult to price and potential losses are staggering).

This list rivals Ready.Gov’s  Risk Assessment (CLICK HERE)  for providing compelling reasons

Deliver to:  Notice.comments@irscounsel.treas.gov 

Introduction

Via IRS Notice 2016-66 (the “Notice”), the Internal Revenue Service (“IRS” or “the Service”) has invited the public to comment regarding how the Service might, via future guidance, articulate a principled distinction between abusive and legitimate captive insurance arrangements taxed under Section 831(b) of the Internal Revenue Code (“Microcaptives”).

I am an attorney and CPA.  I have a Master’s Degree in Accounting with a concentration in taxation.  I have been a licensed insurance broker actively working in the insurance industry for more than a quarter century.  I have been heavily involved with managing captive insurance companies, often of the Microcaptive variety, for more than a decade.  I have various securities licenses, and I am an investment advisor fiduciary to over $10 billion in qualified retirement plan assets.  Given my background in accounting, law, taxation, insurance and investments, I believe that I’m uniquely qualified