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Overview

Chaz is a senior partner in the tax and employee benefits department with over 40 years of experience in tax controversy work, primarily before the Internal Revenue Service and U.S. Tax Court. He also has an emphasis on the taxation of captive insurance companies. He has resolved scores of cases with the IRS relating to federal income, estate, excise, gift and estate taxes, penalties and interest.

Chaz also counsels clients in tax planning, particularly for captive insurance companies and their owners. Chaz was counsel in two of the seminal cases concerning captive insurance: Ocean Drilling & Exploration Company v. United States, 988 F.2d 1135 (Fed. Cir. 1993) (substantial unrelated business captive insurance) and Humana Inc. and Subsidiaries v. Commissioner, 881 F.2d 247 (6th Cir. 1989) ("brother sister" captive insurance).

He is a fellow, and former Regent, of the American College of Tax Counsel and continues to be a nationally recognized leader in the captive insurance tax area.

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
  • Named to Captive Review Power 50 List, 2013-2016
  • Named to Captive Review ERC Pioneer 20 List, 2016
  • Selected for inclusion in The Best Lawyers in America® since 1993 in the fields of Litigation and Controversy - Tax; Tax Law
  • 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 (twice)

Community Involvement

Professional Leadership

  • Current Chair, Captive Insurance Subcommittee of American Bar Association Insurance Companies Committee
  • Past Regent, American College of Tax Counsel
  • Past Chair, Professional Services Committee, American Bar Association Tax Section
  • Past Vice Chair of Personal Service Organizations; Past Vice Chair of Closely Held Business Committee; Past Member Nomination Committee and Tax Court Appointment 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
  • Past Co-Chair, ATLAS Captive Insurance Tax Summit

Civic and Charitable Involvement

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

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
  • Electing to Succeed," U.S. Captive Magazine, April 2010
  • 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
  • Article in 36 Journal of Organic Chemistry 1003

News

Events

Presentations

  • "Lessons from Avrahami v. Commissioner - Captive Best Practices Reiterated," VNAS Captive Educational Conference, November 4, 2017
  • "Tax Summit Panel Avrahami v. Commissioner," "Evolution of Captive Insurance Taxation," "Risk Distribution," "Pools and Other Third-Party Risks," "Section 831(b)," BNA
  • "Take One! Captives 101," Vermont Captive Insurance Association 2016 Annual Conference, August 9-11, 2016
  • 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
  • "Captive Insurance: What is it and How Does it Work?," MCM Insurance Second Annual seminar, November 21, 2013
  • "Captive Educational Conference," VNAS Conference, November 15-17, 2013
  • "Tax and Regulatory Developments and Small Captives," SRS Client Symposium, November 12-13, 201
  • "Pools and Other Third Party Risks – What, Where and Why," "The Evolution of Captive Insurance Taxation," "Risk Distribution: Siblings or Strangers," "Section 831(b) Election, Section 501(c)(15) & Consequences & a Non-Captive Case," Bloomberg/BNA Captive Insurance Tax Summit, October 28-29, 2013
  • "Tax and Regulatory Issues for 831 (b) Captives," SIIA, October 21-23, 2013
  • "RRGs vs. RPGs vs. 831 (b)s," "Future Growth Prospects," NRRA National Conference, October 1-3, 2013
  • "Catch the Ins and Outs of Micro-Captives," SCCIA Annual Conference, September 16-17, 2013
  • "Captive 102: A Selected Overview of Insurance Taxation," VCIA Annual Conference, August 13-15, 2013
  • "Captive Insurance Tax Update," CVG/VNAS Meeting, June 14, 2013
  • "The Ins and Outs of Risk Pooling," "Surviving an IRS Audit," WRCIC, June 11-12, 2013
  • "To Sea or Not to Sea - Onshore vs. Offshore," "Tax Aspects and Captive Taxation: Are the Times A-Changing?," USA Risk 8th Annual Executive Educational Conference, May 21-22, 2013
  • "Dodd Frank and Captives," DCIA Mid Year Forum, May 14, 2013
  • "Successful Strategies for the Exploding Small Captive Market," CICA International Conference, March 10-12, 2013
  • "831(b) Captive," BB&T Insurance seminar, February 26, 2013
  • "Appeals...Other Resolutions...and Selected Items to Watch in 2013," Tax Executives Institute, February 21, 2013
  • "Pools and Other Third-Party Risks - What, Where and Why," "The Evolution of Captive Insurance Taxation," "Risk Distribution: Siblings or Strangers," Bloomberg/BNA/CITE Legal, Tax and Financial Aspects of Captive Insurance, February 11-13, 2013
  • "Forming and Operating a Captive," 16-hour Core Course for the International Center for Captive Insurance Education (ICCIE), Ongoing

  • 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), Ongoing

  • Speaker and Panelist, 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)

Other Media

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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