Other Practice Areas

The Firm has experience in many other practice areas. For example, the Firm:

  • Advises on the appropriate level of tax contingency reserves;
  • Submitted comments to the Treasury Department on matching premium acquisition expenses with related gross premium accelerated under the earned premium regulations under I.R.C. § 832;
  • Processes and develops requests for global interest netting;
  • Developed a deferred compensation program for independent contractor agents to create incentives for marketing;
  • Serves as tax counsel on Congressional legislative projects, advising on technical tax issues and monitoring legislative developments;
  • Advises on the issues involved in obtaining and retaining tax-exempt status for nonlife insurance companies under I.R.C. § 501(c)(15);
  • Advises on information reporting and withholding obligations and penalties with respect to payments under insurance products, foreign transactions and application of tax treaties;
  • Serves as tax counsel for tax-exempt organizations, providing tax advice on various issues including avoiding UBIT and adopting tax-efficient procedures;
  • Advises on the federal excise tax under I.R.C. § 4371;
  • Advises companies of reporting, listing and registration requirements on purported tax shelters; and
  • Submitted comments on the impact of I.R.C. § 409A on deferred compensation arrangements of insurance companies.