P. Bruce Wright counsels multinational clients on a variety of tax and insurance law issues including formation of commercial offshore privately and publicly held entities and the development of structured financial products such as securitizations, swaps, options and similar products used as alternatives to conventional risk financing mechanisms such as “rent-a-captives” and “cell companies.”
Bruce focuses his practice on the representation of property and casualty insurance companies, the formation of single parent/group captive insurers, and counseling risk retention groups. He has extensive experience counseling clients on federal income tax issues such as debt or equity characterization, engaging in U.S. trade or business issues, continuity of interest, passive foreign investment company status, controlled foreign corporation status, limitations on the use of net operating losses, cancellation of indebtedness income, consequences of debt modification, original issue discount, federal excise tax and state premium tax on premiums paid to foreign investors.
© 2013 Sutherland Asbill & Brennan LLP
LL.M., Georgetown University Law Center, 1974
J.D., cum laude, Brooklyn Law School, 1971
B.S., City University of New York, Brooklyn College, 1967
District of Columbia, New York