Dewey & LeBoeuf

P. Bruce Wright

Partner

P. Bruce Wright is a partner in the Tax Department at Dewey & LeBoeuf, where he is involved on a regular basis in tax and insurance law issues. These include representation of property and casualty insurance companies, formation of single parent/group captive insurers, counseling of risk retention groups, and creation of various types of alternative risk financing mechanisms, such as "rent-a-captives" and "cell companies."

His practice has included counseling clients on formation of commercial offshore privately and publicly held entities and the development of structured financial products, such as securitizations, swaps, options and similar products used as alternatives to conventional risk financing mechanisms. As a result of this practice, he has considered numerous federal income tax issues relating to issues such as debt or equity characterization, engaging in US trade or business issues, continuity of interest, passive foreign investment company status, controlled foreign corporation status, limitations on use of net operating losses, cancellation of indebtedness income, consequences of debt modification, original issue discount, federal excise tax and state premium tax on premiums paid to foreign investors.

Mr. Wright speaks regularly at industry conferences, including the Vermont Captive Insurance Association, Captive Insurance Company Association, Hawaii Captive Insurance Association and Nevada Captive Insurance Association.

Publications

Co-author, "Tailor-made Captives," Captive Review, Latin America Report (2011).
Co-author, "Proposed Treasury Reg: Series LLCs and Cell Companies," (April 2011).
Co-author, "Captives: Creeping State Tax Reach," Captive Insurance Company Reports (October 2010).
Co-author, "Update: FET Applies on a Cascading Basis," Captive Insurance Company Reports (March 2010).
Author, "IRS Weighs in on Cell Captives," Captive Insurance Company Reports (April 2008).
Co-author, "Scrutinizing TAM on Partnerships and the True Insured," Captive Insurance Company Reports (August 2008).
Co-author, "IRS Guidance: FET Applies on a Cascading Basis," Captive Insurance Company Reports (May 2008).
Co-author, "Considerations in Forming a Risk Retention Group," AHRMNY News (Spring 2008).
Co-author, "Effects of Proposed IRS Regulation on Tax Benefits of Captives," Risk Financing Perspectives (January 2008).
Columnist, Risk Management (June 1980–April 1995).
Co-author, "The Rules of Insuring Employee Benefits in Captives," Risk Management (August 2002).
Co-author, "Purchasing Insurance from Unlicensed Insurers," Risk Management (August 1998).
Co-author, "Despite IRS Attempts, Captive Wall Remains Intact," Risk Management (September 1991).
Co-author, "Enforceability of the Regulatory and Insured v. Insured," Exclusion in D&O Policies, Bank Risk (April 1991).
Co-author, "FIRREA Enforcement Provisions," Bank Risk (September 1990).
Contributing author, Department of Commerce Report, "The Risk Retention Act — Bane or Blessing?," Society of CPCU (1989).
Contributing author, Risk Financing—A Guide to Insurance Cash Flow, International Risk Management Institute, Inc. (1987).
Contributing author, Essentials of Risk Financing, Insurance Institute of America (1986).

Speeches

Speaker, New Jersey Department of Banking and Insurance Commissioner’s Symposium, East Brunswick, NJ, November 30, 2011
Speaker, 23rd Annual Federal Bar Association Insurance Tax Seminar, Washington, DC, May 26, 2011