Bruce advises clients on a wide range of tax and insurance law issues, including the formation of commercial offshore privately and publicly held entities.
Bruce is nationally recognized as an authority in the captive insurance industry.
He also works with clients on the development of structured financial products such as securitizations, swaps, options and similar products used as alternatives to conventional risk financing mechanisms such as “rent-a-captives” and “cell companies.”
Representing domestic and foreign-based clients, Bruce advises property and casualty insurance and reinsurance companies, guides the formation of single-parent/group captive insurers and counsels risk retention groups. With more than four decades of experience, he has helped clients successfully navigate an array of complex federal income tax issues such as debt or equity characterization, engaging in US trade or business issues, continuity of interest, passive foreign investment company status, controlled foreign corporation status, limitations on the use of net operating losses, cancellation of indebtedness income, consequences of debt modification, original issue discount, federal excise tax and state premium tax on premiums paid to foreign investors.
- Advising financial services corporations and their boards on the NY Department of Financial Services Cybersecurity Regulation, current and proposed SEC cybersecurity requirements, and global privacy rules.
- Tax Update, September 27, 2023, South Carolina Captive Insurance Association Annual Conference
- Update on Federal and State Tax Issues and Significance of Exposure Units in Analyzing Risk Distribution, May 10, 2023, North Carolina Captive Insurance Association Annual Conference
- Focus Points: Procedural Overview of the IRS Audit Process and Cat Bonds, Parametric Coverage and Other ILS, March 22, 2023, 2023 Captive Insurance Tax Forum
- State and Local Taxes, including Direct Placement Taxes, March 22, 2023, 2023 Captive Insurance Tax Forum
- Overview of Cell, Series and Rent-a-Captives, March 22, 2023, 2023 Captive Insurance Tax Forum
- Employee Benefits as Third Party Risk and Delaware law changes permitting certain D&O coverage, March 21, 2023, 2023 Captive Insurance Tax Forum
- Redomiciling of Captive Arrangements, March 21, 2023, 2023 Captive Insurance Tax Forum
- Captive Tax Developments - A Breakthrough Year Speaker, August 10, 2022, Vermont Captive Insurance Association 37th Annual Conference
- Captive Taxation: Nothing Constant but Change, June 28, 2022, Western Captive Insurance Conference
- Tax: Fast-forward, March 8, 2022, 2022 CICA International Conference
- State and Local Tax Update, November 8, 2021, Captive Insurance Company Association
- Hot Topics, October 19, 2021, D.C. Captive Insurance Association
- Tax Update, October 11, 2021, Captive Insurance Company Association Fall Seminar
- Presentation for the North Carolina Captive Insurance Company Association Conference, September 1, 2021, North Carolina Captive Insurance Company Association Conference
- Captive Insurance Tax – The Latest, June 15, 2021, International Center for Captive Insurance Education
- Current Federal and State Income Tax Issues Affecting Captive Insurance Companies, April 29, 2021, Willis Towers Watson Captive Forum
- Federal, State and Local Tax Update, April 22, 2021, Captive Insurance Company Association
- Defining 'Insurance' & Captive Items of Interest, January 26, 2021, ABA Virtual 2021 Midyear Tax Meeting
- Captive Insurance Tax Forum, February 25-26, 2020
- Hot Topics, January 29, 2020, World Captive Forum
- Tax Issues Roundtable, January 28, 2020, World Captive Forum
- Update on Federal and State Tax Law Issues, January 28, 2020, World Captive Forum
- Group Captives: A Case Study and the Big Issues, January 28, 2020, World Captive Forum
- General Session: Hot Topics, January 28, 2020, 2020 World Captive Forum
- Update on Federal and State Tax Law Issues, January 28, 2020, 2020 World Captive Forum
- Group Captives: A Case Study and the Big Issues, January 28, 2020, 2020 World Captive Forum
- Federal and State Tax Update, December 5, 2019, Cayman Captive Forum 2019
- Chapter 6.1: Tax Implications of Risk Financing, November 14, 2019, Risk Financing, published by the International Risk Management Institute
- Captive Insurance Tax Forum, October 28-29, 2019
- How the New Proposed Passive Foreign Investment Company Regulations Affect Captives, September 26, 2019, ABA Business Law Section’s Captive Insurance Committee
- Direct Procurement, Related State Tax Issues and Federal Excise Taxes, September 17, 2019, Minnesota Chapter of the Risk and Insurance Management Society (RIMS)
- An Update of State and Federal Tax Issues, September 11, 2019, South Carolina Captive Insurance Association
- Changes in Federal Tax Law and IRS Regulations 2018-2019, August 23, 2019, North Carolina Captive Insurance Association Conference
- Growing Your Captive With Employee Paid Lines of Coverage, August 22, 2019, North Carolina Captive Insurance Association Conference
- Risk Retention Groups and Risk Purchasing Groups – Opportunities and Problems, June 26, 2019, ABA Business Law Section’s Captive Insurance Committee
- Risk Retention Groups and Risk Purchasing Groups, June 26, 2019, Webinar - ABA Business Section Committee on Captive insurance Companies
- Tax matters, June 19, 2019, Captive Summit Houston
- Tax Issues Affecting Captive Insurance Companies, June 12, 2019, Bermuda Captive Conference
- Tax matters for the newer captive owner, May 23, 2019, Captive Summit Chicago
- Advanced captive tax, May 23, 2019, Captive Summit Chicago
- Employee benefits in captives - What kickstarted the rise? How will it develop? May 23, 2019, Captive Summit Chicago
- Taxation of Captives and Employee Benefits, May 22, 2019, Captive Review Seminar
- Taxation of Captives and Employee Benefits in Captives, May 22, 2019, Captive Summit Chicago
- Self-Procurement Taxes, May 21, 2019, Connecticut Captive Insurance Association Conference
- Taxation of Captives and Employee Benefits in Captives, May 16, 2019, Captive Summit Atlanta
- 101: Captive Tax Developments – What They are and What They Mean, March 12, 2019, CICA 2019 International Conference
- Captive Insurance Tax Forum, February 25-26, 2019
- Captive Tax – New Answers to Old Questions, February 20, 2019, Vermont Captive Insurance Association
- Captive Tax: A New Look At An Old Story, December 11-13, 2018, South Carolina Captive Insurance Conference
- How tax reform will affect your captive program, November 27-29, 2018, Cayman Captive Forum
- Employee Benefits in Captives, November 6, 2018, Marsh Captive Owners Group
- Captive Insurance Tax Forum, October 29-30, 2018
- Texas Captive Summit 2018, October 22, 2018, Captive Review
- Hawaii Captive Insurance Council Annual Conference, October 15-18, 2018, Hawaii Captive Insurance Council
- New York Captive Summit, September 20, 2018, Captive Review
- Annual Federal & State Tax Update, August 20-22, 2018, NC Captive Insurance Association (NCCIA)
- Annual Federal and State Tax Update, August 22, 2018, North Carolina Captive Insurance Association
- Webcast: Section 953(d) Elections – The Election Process May Not Be as Easy as It Appears, August 16, 2018, American Bar Association
- Tax Reform: Where the Dust Settled, August 7-9, 2018, Vermont Captive Insurance Association
- Tax Reform: Where the Dust Settled, August 7, 2018, Vermont Captive Insurance Association
- Webcast: An In-Depth Discussion of the Reserve Mechanical Case, August 1, 2018, American Bar Association
- Rapidly Evolving Tax Landscape in the Captive Industry, June 13, 2018, Bermuda Captive Conference
- Captive Insurance Tax Forum, February 26-27, 2018
- Webcast: Tax Reform & Captives, February 20, 2018, Vermont Captive Insurance Association
- Hot Topics for Captives, February 2, 2018, World Captive Forum
- Taxation of Captives, February 1, 2018, World Captive Forum
Books
- Chapter 6.1: Tax Implications of Risk Financing, November 14, 2019, Risk Financing, published by the International Risk Management Institute.
- Chapter 4: US Taxation of Non-US Captives, Spring 2018, Captive Insurance Deskbook for the Business Lawyer – published by the American Bar Association
- Appendix: The Base Erosion Anti Abuse Tax (BEAT)—Overview, Spring 2018, Captive Insurance Deskbook for the Business Lawyer – published by the American Bar Association
- Named to The Best Lawyers in America in the area of Insurance Law (2023-2024)
- Recognized by Chambers USA: Guide to Leading Business Lawyers in the area of tax (2021-2023)
- Recognized by The Legal 500 United States in the area of international tax (2020-2022)
- Honored as one of the inaugural inductees to the Captive Review "Hall of Fame" (2016)
- Recipient, Distinguished Service Award, Captive Insurance Companies Association (2016)
- Ranked No. 2 in the latest edition of Captive Review magazine’s “Power 50,” which recognizes the 50 most important figures in the international captive insurance community (2014-2015)
- Recipient, Industry Service Award, Vermont Captive Insurance Association (2015)
- Ranked No. 4 in Captive Review magazine’s “Power 50,” which recognizes the 50 most important figures in the international captive insurance community (2013-2014)
- Ranked No. 8 in Captive Review magazine’s “Power 50,” which recognizes the 50 most important figures in the international captive insurance community (2012-2013)
- Recipient, U.S. Captive Outstanding Contribution Award, U.S. Captive Services Awards, Captive Review (2012)
- Ranked No. 9 in Captive Review magazine’s “Power 50,” which recognizes the 50 most important figures in the international captive insurance community (2011-2012)
- Recognized as a distinguished benefactor by the Nevada Captive Insurance Association (2011)
Chair, Captive Insurance Committee, ABA Business Law Section
Former Vice-Chair, Captive Insurance Committee, ABA Business Law Section
- District of Columbia
- New York
- J.D., cum laude, Brooklyn Law School
- B.S., City University of New York at Brooklyn College
- LL.M., Georgetown University Law Center
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