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

Services

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

Admissions

Recognition

Awards

  • The Best Lawyers in America, 2013-2022
    • 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
  • 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
  • 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

News & Insights

Publications

  • Recent U.S. Federal Income Tax Developments for Captive Insurance Companies
    Publication | Michigan Tax Lawyer, Vol. XXXV, Issue 1 |
  • 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

Alerts

Seminars & Events

  • Captive Insurance: Considerations in Taxation
    Event | Grand Cayman, Cayman Islands |
  • 831 (b) Captives - Possibilities and Pitfalls
    Event | Grand Cayman, Cayman Islands |
  • Tax for Taxable (Captive) Entities
    Event |
  • The U.S.-Canada Tax Treaty Protocol: Impacts and Planning Opportunities
    Event | Toronto, ON |
  • Tax Issues for Health Care Organizations: Tax Requirements of Alternative Investments
    Event | Arlington, VA |
  • Tax and Structuring Aspects of Captive Insurance Arrangements
    Event | Bloomfield Hills, MI |
  • Understanding Canada-U.S. Taxation
    Event | Toronto, ON | June 6-7, 2013
  • Tax for Taxable (Captive) Entities
    Event |
  • Fifth Tax Planning for the International Client
    Event | Toronto, ON |
  • Review of Recent US Federal Tax (IRS) Audits
    Event |
  • Third Tax Planning for Migration to or from Canada
    Event | Toronto, ON |
  • International Tax Planning, Compliance and Audit Issues Facing Companies and Individuals: The Inbound and Outbound Perspectives
    Event | Plymouth, MI |
  • 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 |
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