www.captiveinternational.com EDITOR’S LETTER 3
Owen Faulkner, editor, Captive International
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Captive International – ISSN
Cover Image: iStock Photo / Bill Oxford
n this issue of Captive International, we delve into the pending US
Tax Court cases—Caylor v Commissioner, Wilson v Commissioner
and Syzygy v Commissioner—and ask how they might pan out,
and what their impact may be on the small captives sector, and
perhaps the wider captive insurance industry.
It is likely there will be a continued focus on risk distribution in these cases,
and there is a consensus in the industry that these cases may result in further
IRS victories, and in turn more scrutiny of the captives sector.
Nate Reznicek of CIC Services examines Avrahami and Reserve Mechanical,
and argues that these cases aren’t a sign that the sky is falling and risk pools
Also in this issue we have Anne Marie Towle of JLT IM exploring the benefits
of medical stop loss captives, Tatjana Winter of the BlockART Institute
examining parametric risk transfer, and Ciaran Healy of Willis Towers Watson
viewing the current landscape of European captives.
This past month has featured a number of significant industry hires, for
example at offshore law firms Carey Olsen, and captive managers Artex and
Strategic Risk Solutions.
Captive International attended VCIA last month and interviewed a number
of industry executives and reported live on various sessions.
The event, appropriately themed ‘Where the Captive World Come to Meet’,
hosted more than 1,000 delegates—captive owners, managers, and service
providers—from around the world. We found this year’s conference especially
interesting, seeing some of the more innovative ways captives are being used.
Captives continue to be seen as an attractive risk transfer option for
financing unique risks in the more disruptive industries, but can also be
faster to step in and provide coverage where the traditional industry may be
slow to react.
A great example of this was in the ride-sharing industry, for which one panel
suggested captives can have more flexibility to tailor policies and bundle
products, which can be valuable as subscription and usage-based models
become more prevalent. l