In the fifth GCP Short, Richard is joined by Paul Phillips and Mikhail Raybshteyn, Partners at EY, to discuss the importance of risk shifting and risk distribution when thinking about tax qualification for captives in the United States.

Paul and Mike (full biographies below) discuss the difference between risk shifting and distribution, how it can be achieved and demonstrated, the common pitfalls and the consequences when it is not executed correctly.

For more information on the EY Captive Insurance Services team, visit their website: https://www.ey.com/en_us/financial-services/captive-insurance-services

Paul Phillips is a Partner within Ernst & Young LLP (US). He has held various positions within the firm and currently serves as the Chief of Operations and the leader of the Global Compliance and Reporting (GCR) service line for the EY Americas Financial Services Organization (FSO) Tax practice. He also continues to serve as a Co-leader of EY’s Global Captive Insurance Network.

He leads broad and diverse teams spanning a vast geographic footprint. Paul has a proven track record of creating profitable departments and positive work environments while achieving exceptional growth. Throughout his 25-year career, Paul has focused on the taxation of financial institutions and he continues to directly serve various financial firms and alternative risk financing and captive insurance arrangements.

Paul earned his MBA from The Ohio State University Fisher College of Business, his MS in Taxation from DePaul University in Chicago and his BS in Accounting from Southeastern Louisiana University.

Mikhail Raybshteyn is a Partner in EY's Tax practice, with a focus on Insurance sector clients.

For over 15 years, Mikhail has been advising global, multinational and regional Life, Property & Casualty, Health/BCBS, Financial Guarantee and Captive Insurance clients (and Captive Insurance owners). Some of the areas where he has advised clients include all aspects of domestic and global tax accounting and financial reporting (GAAP, IAS and SSAP), Domestic and International tax planning, structuring, and tax financial forecasting and Captive Insurance and alternative risk financing structures.

Mikhail is member of EY Global Captive Network and is the Deputy Leader for EY Americas Captive Insurance Services co-leading a practice of over 40 professionals in the Americas across tax, advisory, risk, and actuarial service lines that comprise EY's Captive Insurance Services practice.

He holds a BBA from Baruch College and an MS from Fordham Gabelli School of Business.

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