Insurance Tax

Tax lawyers at S&C have broad experience with the insurance industry (including life and non-life companies, both stock and mutual), have participated in all aspects of the Firm’s insurance practice (including M&A and capital markets transactions, acquisitions and dispositions through mergers, stock purchases and assumption-reinsurance transactions; and demutualizations and other IPOs, including establishing and taking public offshore insurance companies) and have taken a leading role in designing novel financial products and financing structures for the insurance industry (including closed block financing and tracking stock; structures for risk securitization and premium financing; reinsurance, insurance derivatives and other structures for alternative risk transfer; separate account structures; and hybrid securities and surplus notes offerings).

• Our Tax Group deals regularly with cross-border issues affecting both domestic and foreign companies, advising companies on the domestic taxation of their international operations and non-U.S. companies on the U.S. taxation of their on-shore and off-shore U.S. operations.
• S&C (both its Tax and Litigation Groups) also represents insurers in disputes with the Internal Revenue Service, including matters involving competent authority proceedings; the treatment of failed contracts; the reasonableness of IBNR reserves; the allocation of expenses to U.S. branches of foreign insurers; and fresh start, reserve strengthening and the discounting of loss reserves.