Identifying optimal tax structures important for ILS: Scott Slater, PwC Bermuda

When it comes to establishing insurance-linked securities (ILS) investment management operations, it’s important to identify the optimal structures for tax purposes, our recent interview with Scott Slater of PwC Bermuda shows.

Our latest Artemis Live video interview 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 optimal 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 optimal structure, but also the people functions and the activities that need to happen from Bermuda, to achieve that optimal tax result,” he commented.

The full video interview with PwC Bermuda’s Scott Slater is embedded below and can also be viewed, along with previous Artemis Live video interviews, on our dedicated video page.

https://www.youtube.com/watch?v=xjSL8CB0ppo

You can also listen in audio to all of our interviews by subscribing to the Artemis Live podcast here.

All of our Artemis Live video interviews have a focus on reinsurance, ILS and the efficiency of risk transfer and can be accessed here.

You can also listen in audio to these interviews by subscribing to the Artemis Live podcast here.

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