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Because the benefits of “pure captives” are much more significant, this article is limited to discussing that type of entity (see the sidebar “Case Study” for an example of situations in which it may be advantageous for a small business to set up a captive insurance company). In Risk distribution occurs when particular risks are combined in a pool with other, independently insured risks. 2002-75 the IRS stated that it would begin to issue private letter rulings on specific companies’ risk distribution and risk shifting and whether the captives are true insurance companies.

IDEAL CANDIDATES FOR CAPTIVES The use of a captive should be considered for entities that meet the following criteria: INSURANCE REQUIREMENTS For the premium payment to the captive to be deductible as an insurance expense, the captive must be able to prove that it is a valid insurance company (payments for self-insurance generally are not deductible (, 9 B. By increasing the total number of independent, randomly occurring risks that a corporation faces (i.e., by placing risks in a larger pool), the corporation benefits from the mathematical concept of the law of large numbers in that the ratio of actual to expected losses tends to approach one. There is one additional requirement for the captive to be considered an insurance company for federal purposes.

So start at the upper left, with medical school graduation.

If you’re now an attending (or soon will be) you can start at the bottom left, with residency graduation.

If you are eligible for PSLF (meaning you are employed by a non-profit throughout and after your training) you’ll want to take advantage of that with as much of your debt as possible.

Step 2 is to refinance all private loan debt and enter the Re PAYE program (assuming you can make the payments) with your federal debt.

These insurance subsidiaries or affiliates were often domiciled offshore, especially in Bermuda or the Cayman Islands.

The risk management benefits of these captives were primary, but their tax advantages were also important.

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(NYSE: KMI) Q2 2017 Results Earnings Conference Call July 19, 2017 p.m.

For many years, large corporations in this country have enjoyed many benefits from operating their own captive insurance companies.

Most were established to provide coverage where insurance was unavailable or unreasonably priced.

Private companies that elect the alternative would not consolidate a qualifying VIE, but instead would account for the lease with the VIE (as either capital or operating) and account for any executory contracts between the lessee and lessor (that would have been eliminated if the VIE was consolidated).

How Dell and EMC put this deal together is interesting, as a lot of experts thought a buyout deal of this size could never happen — and certainly not in technology.

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