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Overview

Chaz is a member of the Tax & Employee Benefits Department. He is primarily engaged in federal tax controversy work, but also has an emphasis on the formation, operation and taxation of captive insurance companies. He has resolved scores of cases with the IRS or in the courts relating to federal income, estate, gift and estate taxes, penalties and interest. Chaz also counsels clients in tax planning, particularly for captive insurance companies and their owners.

Career Highlights

Representative Cases and Achievements

  • Ocean Drilling & Exploration Company v. United States, 988 F.2d 1135 (Fed. Cir. 1993) - substantial unrelated business captive insurance
  • Humana Inc. and Subsidiaries v. Commissioner, 881 F.2d 247 (6th Cir., 1989) - "brother sister" captive insurance
  • Resolution of dozens of cases relating to federal income, estate, gift and excise taxes, penalties and interest involving the health care, insurance, natural resources, fast foods, manufacturing, equine and other industries, including definition of insurance, taxation of HMO's as insurance companies, interest computations, mitigation provisions, investment credit, tax accounting, qualification for cash basis accounting, depreciation, accumulated earnings tax, air transportation tax, depletion, fringe benefits, black lung tax, reasonable compensation, valuation, capitalization and cost segregation.

Awards

  • Fellow, American College of Tax Counsel
  • Conferee, United States Tax Court Judicial Conference (Judge's invitation only) (twice)
  • Selected for inclusion in The Best Lawyers in America® since 1993 in the fields of Litigation and Controversy - Tax; Tax Law
  • The Best Lawyers in America® Louisville Tax Law "Lawyer of the Year", 2010, 2014; Louisville Litigation and Controversy – Tax "Lawyer of the Year", 2012
  • Recognized in the Kentucky Super Lawyers® lists, 2008-2011, 2013-2017
  • Faculty, International Center for Captive Insurance Education
  • National Science Foundation grants in Chemistry (two)

Community Involvement

Professional Leadership

  • Immediate Past Chair, Professional Services Committee, American Bar Association Tax Section; Past Vice Chair of Personal Service Organizations; and Past Vice Chair of Closely Held Business Committee
  • Past Member, IRS Central Region Regional Counsel Advisory Group
  • Past Chair and Vice Chair of both Southeast Region IRS - Bar Liaison and Central Regional IRS - Bar Liaison
  • Member, Kentucky Limited Liability Company Initial Legislation Drafting Committee
  • Past Chair, Kentucky and Louisville Bar Association Tax Sections

Civic and Charitable Involvement

  • Kentucky Chamber of Commerce, Past Chairman
  • Leadership Kentucky Foundation, Past Vice-Chair
  • Leadership Kentucky Alumni, Past President 
  • Secretary and Treasurer, KCTCS Foundation, Past and Founding Director 
  • Sergeant at Arms and Director, Downtown Louisville Rotary Club, Past Treasurer
  • University of Kentucky Law School, Visiting Committee 
  • University of Kentucky Law Alumni Association, Past President
  • University of Kentucky Law Dean Search Committee (twice), Past Member

Media

Contributions & Published Works

In addition to written materials for presentations, Chaz serves as author or co-author of other publications, including:

  • "Captive Start-Up Report 2016," Captive Review, May 17, 2016
  • "Changes to 831(b) - What Now," Captive Review, February 2016
  • "Chapter 3: Choice of Entity - Income Tax Considerations," Limited Liability Companies in Kentucky, 3d ed., University of Kentucky Monograph, 2011
  • "Chapter 12: Federal Income Tax Aspects of Operation of an LLC," Limited Liability Companies in Kentucky, 3d ed., University of Kentucky Monograph, 2011
  • "Taxes: The More Things Change, The More They Stay The Same," USA Risk Group 5th Annual Executive Educational Conference, May 26-27, 2010
  • "Captive Roundtable Discussion," Greenebaum Doll & McDonald PLLC, Louisville, KY, May 19, 2010
  • "Electing to Succeed," U.S. Captive Magazine, April 2010
  • "Forming and Operating a Captive," 16-hour Core Course for the International Center for Captive Insurance Education (ICCIE)
  • "US Tax Consequences of Captive Insurance," 2007-2008 U.S. Captive Magazine(Newton Media Ltd.)
  • Principal author of "Loan-back" comments by Vermont Captive Insurance Association (VCIA) and Captive Insurance Companies Association (CICA) in response to IRS Notice 2005-49
  • "IRS Seeks Feedback on Captive Taxation," National Underwriter pp. 30-31, September, 2005
  • Quoted in two different articles of the International Treasurer – the Journal of Global Treasury and Financial Risk Management
  • "Kentucky Tax Law Undergoes Dramatic ‘Modernization’ Through Legislation and Ongoing Regulatory Overhaul," BNA Weekly State Tax Report1, Vol. 2006, No. 43, October 27, 2006
  • Chapter 3 "Choice of Entity - Income Tax Considerations" and Chapter 9 "Federal Income Tax Aspects of Operation of an LLC," Limited Liability Companies in Kentucky, University of Kentucky Continuing Legal Education, 1994 revising 1999
  • "Practice before the IRS Appeals Office after the IRS Restructuring and Reform Act of 1998 with Emphasis on Valuation and Reasonable Compensation" prepared for May 1999 American Bar Association Mini Program that was not held
  • "Recent Developments in Court Procedure," October, 1996, American Bar Association Court Procedure Committee
  • "Taxation of Kentucky Limited Liability Companies," Kentucky Bench & Bar, Winter 1996
  • "Gift and Leaseback: Planning Perspectives in an Unlegislated Field," 63 Kentucky Law Journal 205
  • Article in 36 Journal of Organic Chemistry 1003
  • United States Tax Court Judicial Conference panels:  "Exclusion of Witnesses at Trial," April 19, 2007, Williamsburg, Virginia; "Impact of Financial Accounting Changes on Tax Controversies," April 21, 2005, Farmington, Pennsylvania
  • Co-teach six session course for International Center for Captive Insurance Education (ICCIE) on “Forming and Operating a Captive” (includes two sessions on tax) (numerous times)
  • Co-Chair, speaker and panelist at ATLAS Captive Insurance Tax Summit numerous times, including "Potential Tax Benefits of an Insurance Affiliate," "Onshore Captive Tax and Regulatory Considerations," "Offshore Captive Tax and Regulatory Considerations," "Current IRS Audit Experience and Discussion of Recent Rulings and Cases," "Finding Third Party Risk: Internal & External," and "Basics of Captive Tax Compliance."
  • "Managing Tax Controversies," "Federal Tax Procedure," "Winning at Appeals," and "Section 501(m)" panels and "Taxation of HMOs" speech, Blue Cross/Blue Shield National Tax Conference (numerous)
  • "The Final Piece of Your Destiny - Taxes" and "Gazing into the Captive Crystal Ball," Arizona Captive Insurance Association, Phoenix, Arizona, May 16 and 17, 2007 
  • "Captive Loan-Backs: Loans by Captive Insurance Companies to Their Affiliates," Federal Bar Association, Washington, D.C., June 2, 2006
  • "This is Not About Tax, Correct," Executive Educational Conference (on Captives), Las Vegas, Nevada, May 24, 2006
  • VCIA "Hot Topic" Seminar: "Keeping Current on Taxes," Vermont Captive Insurance Association, Burlington, Vermont, April 19, 2006
  • "Update on Captive Insurance Taxation," South Carolina Captive Insurance Association Conference, Columbia, South Carolina, December 7, 2005
  • "Which Cases Go To Trial" and "Handling Tax Controversies After the IRS Restructuring and Reform Act of 1998," American Bar Association Tax Section, January 21, 2000, San Diego, CA
  • "The Reorganization of IRS Examination," American Bar Association Tax Section, August 6, 1999, Atlanta, Georgia
  • "Selected Income Tax Issues for Physicians," American Bar Association Tax Section, August, 1, 1997, San Francisco, CA
  • "United States Taxation of Premiums Paid to Captive Insurance Companies," TERRALEX Annual Conference, April 18, 1997, Barcelona, Spain
  • "Highlights of Southeast Region IRS Bar Liaison Meeting," American Bar Association Tax Section January 15, 1999, Orlando, Florida, January 23, 1998, San Antonio, Texas, and January 10, 1997, Scottsdale, AZ
  • "Deductibility of Premiums Paid to Captive Insurance Companies," 1990 Offshore Insurance Operations Conference, sponsored by Hartford Institute on Insurance Taxation, January 31, 1990, Washington, D.C.

News

Events

Presentations

  • Captive Insurance Tax Summit - Las Vegas, Bloomberg BNA, February 22-23, 2016
  • "831(b) Captives—The Latest Developments," Strategic Risk Solutions webinar, January 11, 2016
  • "Amendments to §831(b)," American Bar Association Business Law Section, Captive Insurance Committee, December 18, 2015
  • "Captive Taxation: Recent Changes and What’s on the Horizon," Vermont Captive Insurance Association, December 16, 2015
  • "Small Captives - The Current Environment," Strategic Risk Solutions webinar, June 24, 2015
  • Captive Insurance Tax Summit - Las Vegas, Bloomberg BNA, February 23-24, 2015
  • World Captive Forum 2015, Boca Raton, Florida, February 2-4, 2015
  • "Small Captive Feasibility,"  Strategic Risk Solutions webinar, August 5, 2014
  • "Captive Taxation - The Current Environment,"  Strategic Risk Solutions webinar, December 18, 2013
  • "2011 Captive Taxation Update,"  Strategic Risk Solutions webinar, December 13, 2011
  • "Take One! Captives 101," Vermont Captive Insurance Association 2016 Annual Conference, August 9-11, 2016

Services

Industries

University of Notre Dame, B.S., Chemistry Conc., high honors, 1972
University of Kentucky, J.D., 1975
New York University, LL.M., Taxation, 1977

  • Kentucky, 1975
    United States Tax Court
    U.S. District Court, Western District of Kentucky
    U.S. Court of Federal Claims
    U.S. Court of Appeals for the Sixth Circuit
    U.S. Court of Appeals for the Federal Circuit
    U.S. Supreme Court
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