125: Recent international tax developments for re/insurance & ILS: Scott Slater, PwC Bermuda

Published: May 26, 2023, 6:55 a.m.

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Establishing insurance-linked securities (ILS) investment management operations and the impact of recent international tax developments in the industry was the focus of our latest Artemis Live video interview.\\xa0
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\\nOur latest Artemis Live podcast episode is with Scott Slater of PwC, a Partner and the Tax Services Leader at PwC Bermuda.
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\\nScott also leads PwC in the Caribbean\\u2019s International Tax Services group, which is based in Bermuda and the Cayman Islands.
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\\nIn this interview we discussed some recent international tax developments and how they could affect insurance, reinsurance and also insurance-linked securities (ILS) interests.
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\\nSlater explained that a key area of focus for his practice and team, in relation to insurance-linked securities (ILS) market participants, is the controlled foreign corporation (CFC) rules and the passive foreign investment company (PFIC) rules.
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\\n\\u201cIn the ILS space, most of these structures are either CFC\\u2019s or PFIC, and our practice specialises in giving the information that those US investors need to complete their tax returns and satisfy their reporting requirements for making that foreign investment,\\u201d he said.
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\\nSlater also explained that a component of the work his team at PwC undertakes is to help ILS investment managers identify the right structures for their businesses, from a taxation point of view.
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\\n\\u201cIt's an interesting conversation, particularly with those asset manager backed ILS vehicles, to explain to them what has to happen in Bermuda and the people they need to get in Bermuda to satisfy those requirements, to mitigate the risk that they've somehow created a taxable presence in the US.
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\\n\\u201cSo we work with a lot of clients around the structure, but also the people functions and the activities that need to happen from Bermuda, to achieve that tax result,\\u201d he commented.\\xa0
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\\nListen to this podcast episode for more insights from PwC Bermuda's Scott Slater.
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