Artemis Live - Insurance-linked securities (ILS), catastrophe bonds (cat bonds), reinsurance 125: Recent international tax developments for re/insurance & ILS: Scott Slater, PwC Bermuda
May 26, 2023
13:21
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.
Our latest Artemis Live podcast episode is with Scott Slater of PwC, a Partner and the Tax Services Leader at PwC Bermuda.
Scott also leads PwC in the Caribbean’s International Tax Services group, which is based in Bermuda and the Cayman Islands.
In this interview we discussed some recent international tax developments and how they could affect insurance, reinsurance and also insurance-linked securities (ILS) interests.
Slater 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.
“In the ILS space, most of these structures are either CFC’s 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,” he said.
Slater 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.
“It'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.
“So 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,” he commented.
Listen to this podcast episode for more insights from PwC Bermuda's Scott Slater.
Our latest Artemis Live podcast episode is with Scott Slater of PwC, a Partner and the Tax Services Leader at PwC Bermuda.
Scott also leads PwC in the Caribbean’s International Tax Services group, which is based in Bermuda and the Cayman Islands.
In this interview we discussed some recent international tax developments and how they could affect insurance, reinsurance and also insurance-linked securities (ILS) interests.
Slater 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.
“In the ILS space, most of these structures are either CFC’s 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,” he said.
Slater 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.
“It'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.
“So 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,” he commented.
Listen to this podcast episode for more insights from PwC Bermuda's Scott Slater.