Overview
Mike Domanski is a seasoned attorney with a practice dedicated to international tax matters and alternative risk financing arrangements. He possesses more than 20 years of experience representing individuals and companies involved in U.S. inbound and outbound transactions and multi-state arrangements.
- Advises tax-exempt and for-profit entities in the design, implementation 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) and state 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 and state premium tax aspects of international and captive insurance transactions, including matters related to Subpart F / related party insurance, passive foreign investment companies, non-controlled foreign corporations unrelated business income tax, withholding tax obligations, hybrid instruments, foreign tax credits, entity classification and deductibility, domestication elections, US trade or business 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), FinCEN Form 114 / FBAR, state procurement tax forms and Bureau of Economic Analysis survey forms
- Assists clients in assessing their financial reporting obligations in accordance with accounting requirements, such as FIN 48, FAS 5/ASC 450-20, and APB 23/ASC 740.
Services
Practice Areas
Industries
Experience
Prior Experience
- KPMG LLP, Midwest International Corporate Services Group
- PricewaterhouseCoopers LLP, International Tax Practice, Boston, MA
Academic Appointments
- Canadian American Business Transactions, University of Detroit Mercy School of Law, Guest Lecturer
Credentials
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.
Admissions
- Michigan
Recognition
Awards
- The Best Lawyers in America, 2013-2023
- Recognized in practice area of Tax Law
- Detroit Tax Law "Lawyer of the Year," 2021
- Leading Lawyers Magazine Michigan, 2017
- Recognized in practice areas of:
- Insurance, Insurance Coverage & Reinsurance
- International Business & Trade Law
- Tax Law: Business
- Recognized in practice areas of:
- DBusiness, Top Lawyers, 2014-2017
Professional & Community Involvement
- 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
- Tax Law Section
- 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
- Joint JD/LLB program between the University of Detroit Mercy School of Law and University of Windsor Faculty of Law
- Former Advisory Board Member