Practice Area

Insurance & Related Industries

I partner with insurers, brokers, reinsurers, investment banks, and other service providers to navigate the intricate U.S. federal and state insurance tax landscape.

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Federal Excise Tax Mergers & Acquisitions Highlighted Transactions Captives & Global Programs

Federal Excise Tax (FET)

Deep experience across every stage of FET compliance and strategy for complex insurance and reinsurance transactions.

  • Analyze FET applicability to complex insurance and reinsurance transactions

  • Review treaty-based FET exemptions, including foreign branches and LoB clauses

  • Negotiate closing agreements with the IRS

  • Manage quarterly filings, deposits, and payments

Mergers, Acquisitions & Business Formations

Strategic tax counsel on M&A, reinsurance transactions, and cross-border operations across the insurance sector.

  • Advise on tax aspects of M&A and related reinsurance transactions

  • Structure cross-border operations to optimize income and premium tax results

Highlighted transactions

  • First merger of mutual life insurance companies, obtaining an IRS private letter ruling that the merger qualified as a Type A reorganization

  • Pioneering demutualizations and subsequent IPOs

  • Early‑stage insurance securitizations

  • Complex product liability structure, with the client taking a  > $500 M tax deduction while minimizing state self‑placement tax and FET

  • Privatization of state workers’ compensation fund

  • Life‑insurer acquisition from state rehabilitation—clarifying interactions among state insolvency, federal bankruptcy, and Type G reorganization requirements

  • FET analysis for life‑insurer line‑of‑business disposition via assumption reinsurance

  • Cross‑jurisdictional tax advice for a multinational financial‑services provider

TRANSACTIONS

Captives & global programs

  • Design and tax-optimize captive insurance companies and global programs

  • Issue tax opinions confirming risk-shifting and risk-distribution compliance

  • Advise on state self-placement taxes and premium-tax minimization

Sample Work

Assisted numerous U.S. clients in meeting IRS deductibility standards for captive insurance companies, in both U.S. and offshore domiciles, and reviewed self-placed programs for FET and self-placement tax compliance.

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Every engagement begins with a conversation. Reach out to explore how I can support your organization.

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