Mike Domanski

ICCIE elective: Healthcare Captives Overview

Mr. Domanski is a seasoned attorney with a practice dedicated to international
tax matters and alternative risk financing arrangements. He possesses more
than 15 years of experience representing individuals and companies involved
in U.S. inbound and outbound transactions.

  • Advises tax-exempt and for-profit entities in the organization and
    maintenance of captive insurance companies, self-insurance programs,
    risk purchasing groups, rent-a-captives and risk retention groups
  • Counsels clients in the development of structures that are tax-efficient
    from a U.S. and foreign perspective in the context of cross-border joint
    ventures, mergers and acquisitions, financings, and reorganizations
  • Represents clients in connection with Internal Revenue Service
    examinations of international and captive insurance transactions
  • Provides recommendations regarding captive domiciles, ownership
    structure, insurance policy provisions, funding approaches and intercompany
    agreements from a legal and tax perspective
  • Assists U.S. and non-U.S. companies, non-resident alien individuals and
    U.S. expatriates navigate through tax treaty issues and manage tax
    exposures at home and abroad
  • Analyzes U.S. federal income and excise tax implications of international
    and captive insurance transactions, including matters related to Subpart F
    / related party insurance / anti-deferral rules, unrelated business income
    tax, withholding tax obligations, hybrid instruments, foreign tax credits,
    entity classification and deductibility, 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, 1118, 1116,
    926, 720, 1120-PC, 1120-F, W-8 / W-9 / FATCA and FinCEN Form 114 /