2018 Insurance Tax Seminar



 

The insurance industry is constantly evolving, offering new and improved products to meet the needs of a changing demographic, and adopting new approaches to deal with changes in tax rules and regulatory requirements. The intersection of these rules for insurance companies is an increasingly complex landscape that calls for insurance tax professionals and IRS representatives to work closely and efficiently. The FBA Section on Taxation once again provides a forum for both sides to share information, exchange ideas, and forge networking relationships with others in the industry. Learn from experts about recent changes affecting the industry as a result of the Tax Cuts and Jobs Act, and best practices for tax planning and compliance.

Three Ways to Register:
1) Register Online
2) Fax the PDF Registration Form to 571-481-9090
3) Mail the PDF Registation Form to Federal Bar Association; Attn: 2018 Insurance Tax Seminar; PO Box 79395; Baltimore, MD 21279 
 
 

 Early Bird
(on or before 5/6/18)

 Regular
(after 5/6/18)

FBA Sustaining Member  

 $475

$520

FBA Member

$500

$550

Nonmember

$680

$730

Government

$125

$135

Student

$90


 


Thursday, May 31
7:45-8:45 a.m. Registration and Continental Breakfast
8:45-8:55 a.m. Introduction and Welcome by the Seminar Coordinators

Lori J. Jones, Partner, Scribner Hall & Thompson LLP
Alexis A. MacIvor, Branch Chief, Insurance Branch, FI&P, Office of Chief Counsel, I.R.S.
9:00-10:00 a.m. SESSION 1: TAX CUTS AND JOBS ACT: A HIGH-LEVEL OVERVIEW

This opening session will provide a high-level overview of the changes affecting insurers in the Tax Cuts and Jobs Act.  The panel will also discuss the status/likelihood of a technical corrections bill.

Pamela Olson, U.S. Deputy Tax Leader & WNTS Leader, PriceWaterhouse Coopers LLP (moderator)
Philip M. Jacobs, Principal, U.S. Insurance Tax Sector Lead, KPMG LLP
Matthew MacMillen, Vice President, Corporate Tax and Investment Accounting and Operations, Lincoln Financial Group
Joseph B. Sieverling, Senior Vice President and Director of Financial Services, Reinsurance Association of America
10:05-11:05 a.m. SESSION 2A: LIFE COMPANY TAX ISSUES: TAX REFORM AND AUDIT ISSUES

This panel will discuss in depth the technical changes to subchapter L as applicable to life companies in the Tax Cuts and Jobs Act and potential technical corrections/IRS guidance.  The panel will also discuss current audit issues facing life insurance companies and any recent IRS rulings on life company tax issues.  

Sheryl B. Flum, Managing Director, Washington National Tax, KPMG LLP (moderator)
Sanjeev Doss, Head of Tax Planning, Brighthouse Financial
Michael J. Pelzel, Vice President Tax, Ameriprise Financial
Alexis A. MacIvor, Branch Chief, Insurance Branch, Office of Chief Counsel (FI&P), I.R.S.

SESSION 2B: HOW WILL THE NEW “TERRITORIAL” SYSTEM AFFECT INSURERS?

This panel will begin with a high-level overview of the new territorial system and its limitations and uncertainties.  It will also discuss in detail the technical application of the specific provisions in the Tax Cuts and Jobs Act to insurers with international operations or investments. 

Clarissa C. Potter, Principal, Tax, KPMG LLP (moderator)
Paul Aronoff, Vice President, Corporate Counsel, Prudential Financial Inc.
Eric Miller, Senior Tax Counsel, AIG
Steven D. Jensen, Senior Counsel, International, Office of Chief Counsel, IRS

11:05-11:20 a.m. Break
11:20 a.m.- 12:20 p.m. SESSION 3A: LIFE COMPANY TAX RESERVES: TAX REFORM, PBR, AND AUDIT ISSUES

This panel will provide an in-depth discussion of the changes in the Tax Cuts and Jobs Act to the computation of life insurance reserves and new rules on changes in basis in computing reserves.  It will also focus on any relevant audit issues relating to the computation of reserves such as the tax status of the Industry Issue Resolution request with respect to Principle-Based Reserves.  

Art Schneider, Consultant, Transamerica (moderator)
Scott L. Lenz, Vice President and Deputy General Counsel, New York Life
Regina Y. Rose, Vice President, Taxes & Retirement Security, American Council of Life Insurers
Peter H. Winslow, Partner, Scribner, Hall & Thompson LLP
Shafron E. (Shay) Hawkins, Legislative Assistant for Senator Tim Scott (R-S.C.)

SESSION 3B: BEAT AND GILTI ANTI-ABUSE PROVISIONS IN THE NEW TERRITORIAL SYSTEM

This panel will focus on the application of the new anti-abuse rules in the territorial system and how the rules are expected to impact insurer operations/investments in the U.S. and foreign countries.  Specifically, the panel will discuss the base erosion (BEAT) and anti-abuse tax  and the new global intangible low-taxed income (GILTI) provisions.

Angela J. Walitt, Partner, Baker McKenzie LLP (moderator)
Richard J. Burness, Senior VP and Global Head of Tax, Athene Holding Ltd.
Frederick Peurye, VP Taxation, Great-West Financial
Brenda Viehe-Naess, Attorney, Washington Advocates Group
D. Peter Merkel, Senior Technicianl Reviewer, International, Office of Associate Chief Counsel, IRS

SESSION 3C: STATE AND LOCAL TAX ISSUES

This panel will discuss relevant state and local tax issues that affect insurance companies and new issues that could arise at the state and local level as a result of the Tax Cuts and Jobs Act.

Timothy Mahon, Principal, Financial Services, Ernst & Young LLP (moderator)
Eugene Capobianco, Corporate Vice President, Tax Department, New York Life
Sahang-Hee Hahn, Assistant Vice President & Counsel, MassMutual Financial Group

12:30-1:45 p.m. LUNCHEON AND ADDRESS
Introduction: Brion D. Graber, Partner, Scribner, Hall & Thompson LLP

Preston Rutledge, Assistant Secretary Of Labor at the Employee Benefits Administration
2:00-3:00 p.m. SESSION 5A: PROPERTY/CASUALTY COMPANY TAX ISSUES: TAX REFORM AND AUDIT ISSUES

This panel will discuss the changes to the taxation of property/casualty companies, including changes in tax reserves, under the Tax Cuts and Jobs Act.  It will also discuss any common audit issues affecting property/casualty insurers and possibly how those issues are affected by the Act. 

Kristan Rizzolo, Partner, Eversheds-Sutherland LLP (moderator)
Margaret Labno, Vice President, Tax and Accounting Policy, Property Casualty Insurers of America
Scott Rynda, Senior Vice President Corporate Tax, The Travelers Companies Inc.
Kathryn M. Sneade, Attorney, Insurance Branch, Office of Chief Counsel (FI&P), I.R.S
Lawrence White, Actuary, I.R.S

SESSION 5B: GENERAL UPDATE ON INTERNATIONAL TAX ISSUES

This panel will focus on a pot pourri of international tax issues which affect insurance companies, such as the determination of whether a business constitutes a U.S. trade or business, measuring earnings and profits of foreign operations, and an overview of new international information reporting provisions.  

John J. Peel, Partner, PriceWaterhouse Coopers LLP (moderator)
Denise Hintzke, Tax Managing Director, Deloitte Tax LLP
Surjya Mitra, Managing Director, PriceWaterhouse Coopers LLP
Wayne Schonland, Vice President and Chief Tax Officer, Everest Re Group, Ltd. 
Steven D. Jensen, Senior Counsel, International, Office of Chief Counsel, IRS

SESSION 5C: UPDATE ON PARTNERSHIP AUDIT RULES

This panel will provide an update on the new partnership audit rules and discuss how the new rules could or should impact on the terms of a partnership agreement. 

Eric B. Sloan, Partner, Gibson Dunn & Crutcher LLP (moderator)
Ossie Borosh, Principal, KPMG LLP
Glenn Dance,  Managing Director, Grant Thornton
Brendan O'Dell, Attorney-Advisor, Office of Tax Policy, Treasury

3:05-4:05 p.m. SESSION 6A: LB&I CAMPAIGNS - LESSONS LEARNED FROM IRS' PERSPECTIVE

This panel will provide an update on the IRS LB&I campaigns and lessons learned from the IRS point of view as a result of the campaign approach.  

Ruth Perez, Principal, PriceWaterhouse Coopers LLP (moderator)
Barbara B. Franklin, Deputy Division Counsel (Operations) LB&I, IRS
Helen M. Hubbard, Associate Chief Counsel, Financial Institutions & Products, Office of Chief Counsel, IRS
Gloria C. Sullivan, Director, Enterprise Activities, LB&I Division, IRS


SESSION 6B: PRODUCT TAX UPDATE

This panel is intended to update attendees on federal income tax issues impacting insurance products, including the impact of tax reform on product taxation and design, treatment of investment advisory fees under qualified and nonqualifed contracts, consequences of changes to the IRS Priority Guidance Plan, treatment of missing participants and beneficiaries and developments affecting IRAs and section 403(b) annuities.  

Mark E. Griffin, Partner, Davis & Harman LLP
Eric G. Lanning, Vice President & Senior Counsel, Lincoln Financial Group
Chris Phanco, Assistant Vice President & Tax Counsel, Pacific Life Insurance Company
Lauson C. Green, Special Counsel, TEGE, Office of Chief Counsel, IRS

SESSION 6C: HEALTH INSURANCE COMPANY TAX ISSUES

This panel will include an update on the health insurance company tax issues, including the  ACA,  after the Tax Cuts and Jobs Act.  It will also include an overview of recent developments in the tax issues affecting health insurance companies in audits.

Maria O. Jones, Member, Miller & Chevalier LLP (moderator)
Megan Z. Lansden, Partner, Financial Services, Tax, Ernst & Young LLP
Kevin Owens,  Executive Director, Plan Tax and Financial Regulatory Services, Blue Cross Blue Shield Association
Rebecca L. Baxter, Assistant Branch Chief, Insurance Branch, Office of Chief Counsel (FI&P), I.R.S.

4:05-4:20 p.m. Break
4:20-5:20 p.m. SESSION 7A: TAX/CAPITAL PLANNING/FINANCIAL REPORTING AND CORPORATE STRATEGY

This panel will focus on the perspective of the insurance company and how federal income tax matters are relevant for purposes of managing the amount of capital and satisfying risk based capital requirements.  This panel will also discuss the book impact of tax reform and the rate reduction on DTAs, DTLs, and any relevant guidance from FASB on these matters. 

Tracy D. Williams, Partner, Sidley & Austin LLP (moderator)
Stephen R. Baker,  Vice President, Tax, Symetra Financial Corporation
Thomas Gibbons, Senior Vice President, Pacific Life Insurance Company
Kai Talarek, Partner, Oliver Wyman

SESSION 7B: COMMON INFORMATION REPORTING ISSUES

This panel will discuss common information reporting issues with respect to insurance products. 

Gregory K. Oyler, Partner, Scribner Hall & Thompson LLP (moderator)
Ernest V. Molinari, Vice President & Corporate Counsel, Prudential Financial
Colleen Phalen, Product Tax Senior Manager, CUNA Mutual Group

SESSION 7C: WHAT RISKS QUALIFY AS INSURANCE RISKS AND WHY?

The panelists will review business, political, and economic risks and will discuss whether they can qualify as insurance risk. 

Walker Johnson, Partner, Steptoe & Johnson LLP (moderator)
Michael Angelina, Executive Director, Academy of Risk Management & Insurance, Saint Joseph’s University
Randy Beckie, Managing Director, Frontrunner Captive Management LLC
Jim McNichols, Professor, Risk Engineering & Systems Analytic Center, Clemson University
John E. Glover, Senior Counsel, Insurance Branch, Office of Chief Counsel (FI&P), I.R.S.

5:30-7:00 p.m. RECEPTION - All registrants welcome
Friday, June 1
7:45-8:25 a.m. Registration and Continental Breakfast
8:25-8:30 a.m. Introduction and Reminders
8:30-9:15 a.m. PLENARY SESSION: UPDATE FROM THE INSURANCE BRANCH

This session includes representatives from the Insurance Branch who will discuss advice, letter rulings, and guidance issued by the Branch within the last year and current projects being considered by the Branch.

Alexis A. MacIvor, Branch Chief, Insurance Branch, Office of Chief Counsel (FI&P), I.R.S. (moderator)
Rebecca L. Baxter, Assistant Branch Chief, Insurance Branch, Office of Chief Counsel (FI&P), I.R.S.
John E. Glover, Senior Counsel, Insurance Branch, Office of Chief Counsel (FI&P), I.R.S.
Dan Phillips, Attorney, Insurance Branch, Office of Chief Counsel (FI&P), I.R.S.
Kathryn M. Sneade, Attorney, Insurance Branch, Office of Chief Counsel (FI&P), I.R.S.

9:20-10:20 a.m. SESSION 8A: INVESTMENT TAX UPDATE (INCLUDING TAX REFORM)

This panel will provide an overview of the provisions in the Tax Cuts and Jobs Act which affect the taxation of investments from an insurance company perspective.  It also would include a discussion of any common audit issues with respect to the taxation of investments.

Frank Strong, Managing Principal, Financial Instruments Group, Deloitte LLP (moderator)
Alan Fu, Vice President and Tax Counsel, Prudential Financial Inc.
Helen P. Herbert, Head of Investments Tax, Tax Department, Brighthouse Financial

SESSION 8B: TAX REFORM AND EMPLOYEE COMPENSATION AND BENEFITS

This panel will discuss changes in the compensation area under the Tax Cuts and Jobs Act, including the elimination of the performance-based exception to section 162(m) and the transitional rule, and changes to the deductibility of fringe benefits and retirement plans.

Margaret (Meg) R. McIntyre,  Senior Associate, Hogan Lovells LLP (moderator)
Michael L. Hadley, Partner, Davis & Harman LLP
Daniel L. Hogans, Principal, Groom Law Group
Janine Cook, Deputy Associate Chief Counsel, TEGE/EOEG, Office of Chief Counsel, IRS

SESSION 8C: TAX TRANSFORMATION – WHAT WILL AN INSURANCE TAX DEPARTMENT LOOK
LIKE IN 5 YEARS?


This panel will discuss the latest developments in tax technology and try to project how Tax Reform and technology will change the operation of tax departments within insurance companies over the next five years.

Dave Altschuler, Senior Manager, Deloitte LLP (moderator)
Karen Bain,  Vice President – Head of Tax, New York Life
Cherie Pashley, Senior Vice President Tax and Treasury, UNUM
Joseph D. Vaccaro, Global Director of Tax, MetLife Inc.

10:20-10:40 a.m. Break
10:40-11:40 a.m. SESSION 9A: ETHICS AND CYBERSECURITY ISSUES

This panel will discuss the ethical issues and requirements raised by cybersecurity concerns in the insurance industry.

Stewart Baker, Partner, Steptoe & Johnson LLP (moderator)
Neal Pollard, Director, Cyber Incident and Threat Management, PriceWaterhouse Coopers LLP
Susan Seabrook, Partner, Eversheds-Sutherland LLP

SESSION 9B: THE PROCESS OF TAX REFORM

This panel will discuss the process of tax reform, including the process that led to the recent Tax Cuts and Jobs Act. The panel may also discuss the legislative process Including technical corrections and preparation of the Blue Book after the enactment of new tax legislation.

Randy Hardock, Partner, Davis & Harman LLP (moderator)
Harvey Blitz, Consultant, Harvey Blitz Consulting
Cecily W. Rock, Senior Legislation Counsel, Joint Committee on Taxation
Karl Russo, Senior Economist, Joint Committee on Taxation

11:45 a.m.-12:30 p.m. TAKEAWAY PANEL/Q&A 

This panel will summarize key points from all of the panels presented in the Seminar and answer any questions posed to the panel by attendees. 

Michael Chesman, Senior Vice President, Associate General Counsel & Director of Tax Law, Hartford (moderator)
Jean Baxley, Managing Director, Deloitte Tax LLP
Lori Robbins, Managing Director, KPMG Washington National Tax
Mark S. Smith, Managing Director, PriceWaterhouse Coopers LLP
J. Howard Stecker, Executive Director, Insurance Tax, Ernst & Young LLP

12:30 p.m. BOX LUNCHES AVAILABLE

The room block at the JW Marriott is now sold out.

An alternative room block is available. Please contact Laura Mulhern (lmulhern@fedbar.org) if you need housing.



Please contact Jordan Weiss if you are interested in sponsoring this conference.

Date
May 31 - June 1, 2018
Location
JW Marriott
1331 Pennsylvania Ave NW
Washington, DC 20004
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