Reinsurance transactions and captive insurance arrangements have long been subjected to scrutiny by the Internal Revenue Service, and transfer pricing considerations in general have become increasingly important to multinational corporate groups with insurance company members. The perceived need for increased rigor in regulating and accounting for these arrangements is a high-profile issue in the insurance community. The fervor surrounding this tropic is underscored by the issuance of New York State Department of Financial Services’ June 2013 report on “Shadow Insurance;” the NAIC’s June 2013 White Paper, "Captives and Special Purpose Vehicles"; and the OECD’s July 2013 "Report to the G20 Finance Ministers and Central Bank Governors: Base Erosion and Profit Shifting (BEPS) and Automatic Exchange of Information."
There is no time like the present to refresh your understanding of the transfer pricing and IRC § 845 landscape, as well as learn about tax best practices for analyzing, structuring and documenting transactions with transfer pricing features, especially reinsurance and captive insurance transactions.
In the course of the webinar, the speakers will cover:
Prerequisite: NoneLevel: IntermediateDelivery method: Group Internet LiveRecommended CPE credit: 1.5 credits
Susan E. Seabrook, Julie Goosman
Susan E. Seabrook is a partner in the Washington, DC office of Bingham where her practice is concentrated in the area of federal tax controversy and litigation, with an emphasis on the special provisions applicable to the insurance, reinsurance and health care industries. Her insight and technical tax knowledge have guided clients to successful resolutions of complex tax controversy matters, frequently at an early stage of administrative development. She has extensive experience at all levels of tax administration and has tried numerous cases before the United States Tax Court. Susan has also advised clients in responding to congressional regulatory and other governmental inquiries as well as provided advice in connection with insurance company and product-related tax implications of complex M&A transactions.
Prior to joining the firm, Susan served as an attorney adviser in the National Office of Chief Counsel, IRS, Financial Institutions and Products. As IRS industry counsel for the life insurance industry, she assisted in identifying and developing issues related to insurance company and product tax. Susan also served as an IRS senior trial attorney and special assistant United States attorney, specializing in insurance company litigation.
Susan is a recognized insurance tax expert and was “recommended for all insurance and reinsurance controversy” by Legal 500.
Julie Goosman is a tax partner in the Boston office of PricewaterhouseCoopers, specializing in the area of insurance mergers and acquisitions taxation. Julie has twenty years of public accounting experience with PwC and she has worked extensively in the M&A tax arena, consulting with company management on corporate restructurings, conversion transactions, global planning projects, public offerings, take private and spin-off transactions. Julie has also been heavily involved in performing due diligence reviews of potential targets and potential buyers for both domestic and international operations.
Julie’s industry expertise is primarily in the insurance industry, having worked extensively with domestic and global life insurance companies, blue cross blue shield organizations, and property and casualty insurance companies, as well as insurance brokerage operations.