Photo of Michael W. DomanskiPhoto of Michael W. Domanski

Michael W. Domanski

Partner
Leader, Insurance Tax Practice Group

Education

New York University School of Law, LL.M.
  • Taxation
Michigan State University College of Law, J.D.
  • magna cum laude; Two American Jurisprudence Awards
  • Journal of International Law and Practice, Business Editor
University of Toronto, B.A.

Prior Employment

  • KPMG LLP, Midwest International Corporate Services Group
  • PricewaterhouseCoopers LLP, International Tax Practice, Boston, MA

Bar Admissions

  • Michigan

Professional Affiliations

State Bar of Michigan

  • Tax Law Section
    • Former Council Member
    • International Committee, Former Chair
  • International Law Section
    • Former Council Member
    • Business and Tax Committee, Former Co-chair 

American Bar Association

  • Tax Section

International Fiscal Association

French-American Chamber of Commerce

Canadian-US Business Association

German-American Chamber of Commerce

Japanese Business Society of Detroit

Overview
Community
News & Resources
Honors

Overview

Mike Domanski is a seasoned attorney with a practice dedicated to international tax matters and alternative risk financing arrangements. He possesses more than 15 years of experience representing individuals and companies involved in U.S. inbound and outbound transactions.

  • Advises tax-exempt and for-profit entities in the organization and maintenance of captive insurance companies, self-insurance programs, risk purchasing groups, rent-a-captives, and risk retention groups
  • Counsels clients in the development of structures that are tax-efficient from a U.S. and foreign perspective in the context of cross-border joint ventures, mergers and acquisitions, financings, and reorganizations
  • Represents clients in connection with Internal Revenue Service (IRS) examinations of international and captive insurance transactions
  • Provides recommendations regarding captive domiciles, ownership structure, insurance policy provisions, funding approaches, and inter-company agreements from a legal and tax perspective
  • Assists U.S. and non-U.S. companies, nonresident alien individuals, and U.S. expatriates navigate through tax treaty issues and manage tax exposures at home and abroad
  • Analyzes U.S. federal income and excise tax implications of international and captive insurance transactions, including matters related to Subpart F / related party insurance / anti-deferral rules, unrelated business income tax, withholding tax obligations, hybrid instruments, foreign tax credits, entity classification and deductibility, and taxation of premium payments to captive insurance companies
  • Provides advice regarding the preparation of federal tax and information returns impacted by international and captive insurance arrangements, including IRS Forms 8865, 8858, 8833, 8832, 5472, 5471, 1118, 1116, 926, 720, 1120-PC, 1120-F, W-8 / W-9 / FATCA, and FinCEN Form 114 / FBAR
  • Assists clients in assessing their financial reporting obligations in accordance with accounting requirements, such as FIN 48, APB 23, and FAS 5

Community

Joint JD/LLB program between the University of Detroit Mercy School of Law and University of Windsor Faculty of Law

  • Former Advisory Board Member

News & Resources

Publications

  • Recent U.S. Federal Income Tax Developments for Captive Insurance Companies
    (2009)
     
    Michigan Tax Lawyer, Vol. XXXV, Issue 1
  • Coming to America: An Introduction to Tax Planning for U.S. Inbound Transactions
    (December 2006)
     
    Michigan Bar Journal, Volume 85, Number 12
  • International Tax Fundamentals
    (October 2006)
     
    Aspatore Books
  • Returning Home from the U.S. - U.S. Expatriate Tax Rules
    (March 2006)
     
    French Connection
  • Tax-Efficient Structuring in Canada: Choice of Entity Considerations and the Expanding Dynamic of the Unlimited Liability Company
    (2006)
     
    Co-author
    Vol. XXXIII, Issue 1, Michigan Tax Lawyer 16
  • How Canadian ULCs Can Help Efficient Cross-Border Investment
    (November 2005)
     
    Co-author
    International Tax Review, Volume 16, Number 10
  • Foreign Companies Doing Business in the U.S.: Entity Classification and Related Tax Issues
    (Spring 2002)
     
    Co-author
    Michigan International Lawyer, Volume 14, Number 2

Seminars & Events

  • Captive Insurance: Considerations in Taxation, 2015 Cayman Captive Forum, Insurance Managers Association of Cayman, Grand Cayman, Cayman Islands
    December 1, 2015, Co-presenter
  • 831 (b) Captives - Possibilities and Pitfalls, 2014 Cayman Captive Forum, Grand Cayman, Cayman Islands
    December 3, 2014, Co-presenter
  • Tax for Taxable (Captive) Entities, Cayman Captive Forum, Insurance Managers Association of Cayman
    December 2013, Presenter
  • The U.S.-Canada Tax Treaty Protocol: Impacts and Planning Opportunities, Federated Press, Toronto, ON
    November 2013, Lecturer
  • Tax Issues for Health Care Organizations: Tax Requirements of Alternative Investments, The Globalization of Health Care: Opportunities and Potential Pitfalls, American Health Lawyers Association, Arlington, VA
    October 2013, Presenter
  • Tax and Structuring Aspects of Captive Insurance Arrangements, Business Entities and International Law Committees of the State Bar of Michigan Tax Section, Bloomfield Hills, MI
    June 13, 2013, Presenter
  • Understanding Canada-U.S. Taxation, Third Annual Workshop, Toronto, ON
    June 6-7, 2013, Lecturer
  • Tax for Taxable (Captive) Entities, Cayman Captive Forum, Insurance Managers Association of Cayman
    December 2012, Presenter
  • Fifth Tax Planning for the International Client, Federated Press, Toronto, ON
    November 2011, Lecturer
  • Review of Recent US Federal Tax (IRS) Audits, Cayman Captive Forum, Insurance Managers Association of Cayman
    December 2010
  • Third Tax Planning for Migration to or from Canada, Federated Press, Toronto, ON
    November 2010, Lecturer
  • International Tax Planning, Compliance and Audit Issues Facing Companies and Individuals: The Inbound and Outbound Perspectives, 22nd Annual Tax Conference, Taxation Section, State Bar of Michigan, Plymouth, MI
    April 29, 2009, Co-presenter
  • Current Trends in Canada: Cross-Border Lending Transactions, Holding Companies and Income Tax Treaties, Automation Alley
    December 2008
  • Current Trends in Europe: Emerging Markets, Holding Companies, and Supply Chain Management, Automation Alley
    June 1, 2008
  • Choice of Entity Issues in the International Context, State Bar of Michigan Tax Conference
    May 2008
  • International Tax - Demystifying Europe and China, After Hours Tax Law Series, Institute of Continuing Legal Education
    January 2008

Honors

  • The Best Lawyers in America, 2013-2018
    • Recognized in practice area of Tax Law
  • Leading Lawyers Magazine Michigan, 2017
    • Recognized in practice areas of:
      • Insurance, Insurance Coverage & Reinsurance
      • International Business & Trade Law
      • Tax Law: Business
  • DBusiness, Top Lawyers, 2014-2017

Academic Appointments

  • Canadian American Business Transactions, University of Detroit Mercy School of Law, Guest Lecturer