P. Bruce Wright

Practice Areas

Nationally recognized as an authority in the captive insurance industry, Bruce counsels companies on a wide range of tax and insurance law issues, including formation of commercial offshore privately and publicly held entities. 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 U.S. 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 insurance premium excise tax, state premium and income tax on insurance entities including captive insurance companies, and direct procurement tax due from insureds on premium paid to insurers non admitted in the insured’s domicile.