Key elements that make a transaction insurance for tax purposes including risk shifting, risk distributions, common notions of insurance and fortuity.
An introduction to fundamental terminology describing risk transfer and related activities.
Identifying the types of risks a buyer accepts when buying and financing a vehicle. The F&I protection product industry’s answers to mitigating those risks including definition and illustrations of risk transfer.
A review of the various programs available to participate in the profits from F&I products produced at dealerships.
NCFC vs. CFC; Purpose of trust account; Differences in various program types.
What is an Obligor and a DOWC and how do they work.
State and Federal regulation of insurance, reinsurance, and obligor (non‐insurance protections). The role direct writers play in reducing the need for governmental regulatory oversight.
ERM Programs and how they may fit with F&I Reinsurance.
Tax positions for a U.S. corporation licensed as an insurer or conversion from a controlled foreign corporation to a U.S. taxpayer via §953(d) election. Determining insurance company status for tax purposes—§831(b). Non‐controlled foreign corporations.
Defining and building an understanding of control groups and attribution as it relates to business ownership structures.
Review of key records for reinsurance business, legal cases, IRS Code §845 evolution and impact.
Including proposed PFIC regulatory changes.
Dirty Dozen Listing, Timing on Guidance, Audits for 831(b) companies.
IRS Staffing and Approval Process Changes; Original Signature Requirements; How to address a 953(d) election processing errors.
Avraham, RVI, Syzygy
Taxpayer’s Positions, IRS Reactions and Prognosis.
Here come the states and they are looking for income. CA FTB nexus issue and status of case; DOWC/AO Nexus Choice, and Wayfair economic nexus implications
Adrian Corr will provide an update on the current TCI rules and regulatory environment, and comment on revisions under consideration.
Allan Barnes, Delaware Tribe of Indians. The Tribal Domicile is a domestic domicile (a dependent domestic sovereign nation) focused on ARCs for vehicle dealers and similar entities, such as rent-to-own stores, etc. They will discuss the issues that have been raised and addressed over the last year and those still under review.
What Keeps You up at Night? Panel to discuss current F&I issues and hot topics. GAP issues (too many), GM disclosure, new products.
Consumer Financial Protection Bureau. Military Lending Act and Wayfair along with other current updates.
What is a typical investment portfolio for a trust account? Restricted investments? Loans?
Conference delivery method: Group: Live
Day 1: Basic
Prerequisites: None Required
Day 2‐3: Intermediate
Prerequisites: Attendees should include insurance professionals and administrators, risk managers, tax professionals, and consultants or attendance on Day One