Overview

Michael Domanski is a partner and leader of the Insurance Tax Practice Group. He is a seasoned attorney with a practice dedicated to captive insurance with a focus on international transactions. With more than 25 years of international and domestic captive insurance experience, he represents individuals, tax-exempt organizations and private/public companies involved in US inbound and outbound transactions and multi-state arrangements.

  • Advises tax-exempt and for-profit entities in the organization and maintenance of self-insurance programs, risk purchasing groups, segregated portfolios/cells, series LLCs, mutual insurers/reciprocals, stock captive insurance companies and risk retention groups
  • Counsels clients in the development of structures that are tax-efficient from a U.S. federal and state perspective in the context of cross-border joint ventures, mergers and acquisitions, financings, and reorganizations
  • Represents clients in connection with controversies involving the Internal Revenue Service and state agencies
  • Provides recommendations regarding captive domiciles, ownership structure, insurance policy provisions, funding approaches, profit repatriation and inter-company agreements from a legal and tax perspective
  • Analyzes U.S. federal income, federal excise tax and state procurement tax implications of international and captive insurance transactions, including matters related to controlled foreign corporations/Subpart F, passive foreign investment companies, unrelated business income tax, U.S. withholding tax, premium tax deductibility, entity classification, 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, 926, 720, 1120-PC, 1120-F, W-8/W-9 (FATCA) and FinCEN Forms (114/FBAR, Corporate Transparency Act)

Services

Practice Areas

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, 2013-2025
    • Recognized in practice area of Tax Law
    • Detroit Tax Law "Lawyer of the Year," 2021
  • Law Bulletin Media
    • Leading Lawyers, Insurance, Insurance Coverage & Reinsurance, 2017, 2023-2024
    • Leading Lawyers, International Business & Trade Law, 2017, 2023-2024
    • Leading Lawyers, Tax Law: Business, 2017, 2023-2024
  • 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 
  • American Bar Association
    • Tax Section
  • 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 & Insights

Events

  • Captive Insurance: Considerations in Taxation
    Event | Grand Cayman, Cayman Islands | | | Co-presenter
  • 831 (b) Captives - Possibilities and Pitfalls
    Event | Grand Cayman, Cayman Islands | | | Co-presenter
  • Tax for Taxable (Captive) Entities
    Event | | | Presenter
  • The U.S.-Canada Tax Treaty Protocol: Impacts and Planning Opportunities
    Event | Toronto, ON | | | Lecturer
  • Tax Issues for Health Care Organizations: Tax Requirements of Alternative Investments
    Event | Arlington, VA | | | Presenter
  • Tax and Structuring Aspects of Captive Insurance Arrangements
    Event | Bloomfield Hills, MI | | | Presenter
  • Understanding Canada-U.S. Taxation
    Event | Toronto, ON | June 6-7, 2013 | | Lecturer
  • Tax for Taxable (Captive) Entities
    Event | | | Presenter
  • Fifth Tax Planning for the International Client
    Event | Toronto, ON | | | Lecturer
  • Review of Recent US Federal Tax (IRS) Audits
    Event | |
  • Third Tax Planning for Migration to or from Canada
    Event | Toronto, ON | | | Lecturer
  • International Tax Planning, Compliance and Audit Issues Facing Companies and Individuals: The Inbound and Outbound Perspectives
    Event | Plymouth, MI | | | Co-presenter
  • Current Trends in Canada: Cross-Border Lending Transactions, Holding Companies and Income Tax Treaties
    Event | |
  • Current Trends in Europe: Emerging Markets, Holding Companies, and Supply Chain Management
    Event | |
  • Choice of Entity Issues in the International Context
    Event |
  • International Tax - Demystifying Europe and China
    Event | |

Publications

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