2019 Insurance Tax Seminar




The insurance industry is constantly evolving. Longstanding industry tax issues, globalization, and the effects of tax reform are forcing companies to remain agile in a changing environment. Industry tax professionals, consultants, and IRS representatives must navigate open issues and negotiate their way together through changing regulatory and tax regimes. The FBA Section on Taxation facilitates a dialogue between insurance industry and government sector professionals and allows participants to stay up-to-date on the latest tax developments and guidance—and provides an opportunity for professional networking. Throughout the program, subject matter experts from “both sides of the aisle” share information and viewpoints on myriad company tax, product tax, and other relevant insurance tax topics.


There are three ways to register for this national event:
1) Register Online
2) Fax PDF Registration Form to 571-481-9090 for processing
3) Mail PDF Registration Form to the following address for processing
        Federal Bar Association
        Attn: 2019 Insurance Tax Seminar
        PO Box 79395, Baltimore MD 21279-0395
 

Registration Fees

   Early Bird
(on or before 4/26)
 Standard
(after 4/26)
 Sustaining Member   $475  $520
 Member  $500  $550
 Nonmember  $680  $730
 Government/Academic  $125  $135
 Law Student   $90  $90

Payment Methods
Acceptable methods of payment include credit card and check. We can accept exact cash payments onsite on the event date. Registration forms received without payment will not be processed.
Cancellation Policy
No refunds will be made for cancellations received after the close of business on Friday, May 3, 2019. No-shows will be billed. Substitutions may be made at any time upon notification. Please contact Caitlin Rider at
crider@fedbar.org with cancellation and/or substitution requests.


 
THURSDAY - MAY 30
7:45 - 8:45 a.m.

Registration & Breakfast

8:45 - 9:00 a.m.

Introduction & Welcome Remarks

9:00-10:00 a.m.

Session 1
Tax Reform: Past and Prospective
The Tax Cuts and Jobs Act (TCJA), passed in 2017, made substantial changes to the US income tax regime for businesses, and included changes specifically aimed at insurance company taxation. Treasury and the IRS continue to issue guidance on numerous newly passed provisions, and there could be more legislative changes ahead. This panel will address the status of tax reform, past, current, and prospective. Attendees will (1) gain insights regarding the tax reform process and TCJA and (2) obtain opinions and information regarding possible tax law changes going forward.

  • Ann Cammack, Principal, EY (moderator)
  • Speakers to be determined
10:10-11:10 a.m.

Session 2A
Life Company Issues
This panel will focus on technical issues in life insurance taxation including changes to Subchapter L as a result of the Tax Cuts and Jobs Act, recently issued guidance, and current audit issues.

  • Jason Stern, Tax Senior Manager, Deloitte Tax LLP (moderator)
  • Bill Elwell, Vice President & Senior Counsel, Massachusetts Mutual Life Insurance Company
  • Daniel Kheel, Vice President, Tax Planning and Strategy, Metropolitan Life Insurance Company
  • Alexis A. MacIvor, Branch Chief, Insurance Branch, FI&P, Office of Chief Counsel, IRS
  • Regina Rose, Senior Vice President, Taxes & Retirement Security, American Council of Life Insurers

Session 2B
Just BEAT and Nothing but the BEAT

The Base Erosion and Anti-abuse Tax (“BEAT”) introduced as part of the Tax Cut and Jobs Act has the potential to fundamentally change the global insurance markets; but will it? Our panelists will discuss what we know (and don’t know) about the operation of this new statute. Will the soon to be issued final regulations answer the industry’s open questions and concerns? Join this discussion and find out.

  • John Forni, Managing Director, Grant Thornton LLP (moderator)
  • Paul Aronoff, Vice President & Tax Counsel, Prudential Financial, Inc.
  • Richard Burness, Senior Vice President & Global Head of Tax, Athene
  • Jason Kaplan, Principal, International Tax, Deloitte Tax LLP
  • Stuart Katz, Director, International Tax, KPMG LLP
  • Peter Merkel, Branch Chief, Branch 5, ACCI, Office of Chief Counsel, IRS
  • Angela J. Walitt, Attorney-Advisor, Office of Tax Policy, U.S. Department of the Treasury

Session 2C
Compensation and Benefits Issues
Panelists will discuss the latest developments impacting the deductibility of executive compensation and certain business-related expenses, focusing on the elimination of the performance-based exception to section 162(m) and the new rules in effect impacting the deductibility of meals and entertainment, transit pass programs and employer provided parking. The panelists will focus on interim guidance issued by the IRS, specifically Notice 2018-68, Information Release 2018-195, Notice 2018-76 and Notice 2018-99.

  • Ernest V. Molinari, Vice President & Corporate Counsel, Prudential Financial, Inc. (moderator)
  • Deena Devereaux, Senior Technician Reviewer, Branch 7, ITA, Office of Chief Counsel, IRS
  • Ilya Enkishev, Attorney, Executive Compensation Branch, EEE, Office of Chief Counsel, IRS
  • Joseph Kosmalski, Vice President & Tax Counsel, Ameriprise Financial, Inc.
  • Michael Monahan, Principal in Charge, Northeast Human Capital Services Practice, Grant Thornton LLP
  • Amber Salotto, Tax Senior Manager, Deloitte Tax LLP
11:30 a.m.-12:30 p.m.

Session 3A
Life Reserves
The panel will discuss issues encountered in implementing TCJA changes to section 807, including changes to the procedures for effecting changes in basis for computing reserves under section 807(f) and Rev. Proc. 2019-10.

  • Mark Smith, Managing Director, PwC (moderator)
  • Richard Bush, Senior Vice President, Ameriprise Financial, Inc.
  • Hal Kolpak, Manager, EY
  • Daniel Phillips, Senior Counsel, Insurance Branch, FI&P, Office of Chief Counsel, IRS
  • Peter Winslow, Partner, Scribner Hall & Thompson, LLP

Session 3B
Presumed GILTI?
The panel will discuss the Global Intangible Low-Taxed Income (“GILTI”) rules of section 951A and the most-recently issued GILTI guidance. The panel will focus on issues and planning strategies relevant to the insurance industry.

  • Amanda Varma, Partner, Steptoe & Johnson LLP (moderator)
  • Jacob Alter, Assistant Tax Counsel, Metropolitan Life Insurance Company
  • Jeffrey Mitchell, Branch Chief, Branch 2, ACCI, Office of Chief Counsel, IRS
  • Joy Tegtmeyer, Tax Partner, PwC

Session 3C
What’s an Annuity?
Unlike life insurance contracts, the Internal Revenue Code does not contain a comprehensive definition of “annuity contract.” Rather, the definitional requirements for annuity contracts are derived from a number of statutory, regulatory, and common law principles, many of which focus more on what is not an annuity rather than what is an annuity. The panel will explore these authorities and discuss what it takes to be an annuity contract for federal income tax purposes.

  • Bryan Keene, Managing Partner, Davis & Harman LLP (moderator)
  • Tom Christenson, Assistant General Counsel, The Northwestern Mutual Life Insurance Company
  • Eric Lanning, Vice President, Senior Counsel, Lincoln National Corporation
  • Chris Phanco, Assistant Vice President & Tax Counsel, Pacific Life Insurance Company
12:30-2:00 p.m.

Luncheon & Address
Charles P. Rettig, IRS Commissioner

2:00-3:00 p.m.

Session 5A
Property & Casualty Tax 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 2019 priorities for the property/casualty industry.

  • Scott Rynda, Senior Vice President, Corporate Tax, Travelers (moderator)
  • John Glover, Senior Counsel, Insurance Branch, FI&P, Office of Chief Counsel, IRS
  • Daniel J. Kusaila, Partner, Insurance Tax Practice, Crowe LLP
  • Greg Oyler, Partner, Scribner Hall & Thompson, LLP
  • David Pearce, Vice President & Director of Tax Policy, American Property Casualty Insurance Association
  • Kathryn Sneade, Senior Technician Reviewer, Insurance Branch, FI&P, Office of Chief Counsel, IRS

Session 5B
International Potpourri and Post-Tax Reform

This panel will focus on a potpourri of international tax issues which affect insurance companies after tax reform, such as foreign tax credits and expense allocation to various baskets, previously taxed E&P, section 245A, changes to section 367 affecting incorporation of an insurance branch and termination of a section 953(d) election, repeal of section 958(b)(4), PFIC insurance exception and recent OECD focus on taxing a digitalized economy.

  • Surjya Mitra, Managing Director, PwC (moderator)
  • Norman Hannawa, Principal, International Tax, EY
  • Joy Tegtmeyer, Tax Partner, PwC
  • Angela J. Walitt, Attorney-Advisor, Office of Tax Policy, U.S. Department of the Treasury

Session 5C
IRS LB&I Division’s Goals for Insurers
This fiscal year, LB&I set out five ambitious strategic goals: (1) to implement tax reform and other priorities, (2) improve compliance activities, (3) improve its workforce, (4) improve its operations, and (5) improve internal and external communications. This panel will discuss how LB&I plans to meet these goals with respect to insurers.

  • Tom Greenaway, Principal, KPMG LLP (moderator)
  • George Hani, Member, Miller & Chevalier Chartered
  • John C. Hughes, Director, APMA, LB&I, Office of Chief Counsel, IRS
  • Christina Hwang, Senior Vice President & Chief Tax Officer, Allstate Insurance Company
3:10-4:10 p.m.

Session 6A
Changing Dynamics in Reinsurance and M&A Transactions after the TCJA

This panel will provide background regarding the rules governing the federal tax treatment of reinsurance and insurance M&A transactions and will focus on the effects of the TCJA on those outcomes, including the impact of BEAT and GILTI on cross-border arrangements, the implication of the changes to the DAC rules, and issues associated with certain transition liabilities arising from the changes made by the TCJA. In addition, the panel will discuss capital and surplus issues that typically inform the business decisions surrounding reinsurance and insurance M&A transactions.

  • M. Kristan Rizzolo, Partner, Eversheds Sutherland (US) LLP (moderator)
  • Stephen Baker, Vice President, Tax, Symetra Life Insurance Company
  • William Pauls, Managing Director, Deloitte Tax LLP
  • Gary Vogel, Executive Director, EY

Session 6B
Product Tax Update

This panel will update attendees on federal income tax issues impacting insurance products. Topics to include an update on split dollar life insurance arrangements, the mandatory use of the 2017 CSO in 2020, the treatment of investment advisory fees under qualified and nonqualified contracts, new RMD rule guidance, diversification guidance for Uniform Mortgage Backed Securities, life settlement reporting as it relates to corporate acquisitions, changes to the IRS Priority Guidance Plan, and other current legislative and regulatory developments.

  • Robert A. Fishbein, Vice President & Corporate Counsel, Prudential Financial, Inc. (moderator)
  • Shannon Gamache, Assistant Vice President & Counsel, Massachusetts Mutual Life Insurance Company
  • Sarah Lashley, Assistant General Counsel, Transamerica Life Insurance Company
  • Alexis A. MacIvor, Branch Chief, Insurance Branch, FI&P, Office of Chief Counsel, IRS
  • Kathryn Sneade, Senior Technician Reviewer, Insurance Branch, FI&P, Office of Chief Counsel, IRS

Session 6C
Hot Topics in Health Insurance

This panel will include an update on health insurance company tax and product issues arising from the ACA and tax reform. It will also include an overview of the recent developments affecting health insurance companies that have happened with respect to legislation, litigation, and audits.

  • Lori Robbins, Managing Director, KPMG LLP (moderator)
  • Rebecca L. Baxter, Senior Technician Reviewer, Insurance Branch, FI&P, Office of Chief Counsel, IRS
  • James Kress, Tax Director, PwC
    Kevin Owens, Account Executive, Blue Cross Blue Shield Association
4:30-5:30 p.m.

Session 7A
Capital Planning: One Concept to Rule Them All

This panel will discuss the tax implications arising from operations and transactions from legal, actuarial and book accounting perspectives. The discussion will focus on the importance of evaluating decisions from multiple perspectives, and highlight that the enterprise impact of any decision can generate both great and problematic news at the same time.

  • Stephen Baker, Vice President, Tax, Symetra Life Insurance Company (moderator)
  • Kyle Karrenbauer, Tax Senior Manager, Deloitte Tax LLP
  • Kristin Norberg, Assistant Vice President, Tax Actuary, Symetra Life Insurance Company
  • Tracy Williams, Partner, Sidley Austin LLP

Session 7B
Information Reporting Developments

This panel will explain federal income tax issues, and provide an update on developments, on several topics involving information reporting requirements, such as the escheatment to state unclaimed property funds, life settlements, qualified plan loan offsets, the safe harbor relief for de minimis reporting errors, and annuity payments to non-US persons.

  • Mark Griffin, Partner, Davis & Harman LLP (moderator)
  • Lauson Green, Special Counsel, EEE, Office of Chief Counsel, IRS
  • Laurie Hatten-Boyd, Principal, KPMG LLP
  • Mandana Parsazad, Vice President, Tax, American Council of Life Insurers

Session 7C
The Evolving Tax Function

As disruptive trends continue to affect insurance company tax departments, such as global regulatory changes, internal value add pressures, finance digitization, data mining, resource limitations, automation and tax technologies, what does that mean for the future of tax department operating and technology models? This panel will help you make sense of it all as tax departments look to thrive in the digital age.

  • Jeff Webb, Senior Manager, Deloitte Tax LLP (moderator)
  • Bridget Linde, Vice President, Global Tax, RGA Reinsurance Company
  • Jeff Thompson, Vice President, Tax, Assurant, Inc.
  • Jay Turchin, Director, Grant Thornton LLP
5:30-7:00 p.m. Reception - All Registrants Welcome
FRIDAY - MAY 31
7:45-8:25 a.m.

Registration & Breakfast

8:25-8:30 a.m.

Introduction & Reminders

8:30-9:10 a.m.

Plenary Session
Update from the Insurance Branch

  • Alexis A. MacIvor, Branch Chief, Insurance Branch, FI&P, Office of Chief Counsel, IRS
  • Rebecca L. Baxter, Senior Technician Reviewer, Insurance Branch, FI&P, Office of Chief Counsel, IRS
  • John Glover, Senior Counsel, Insurance Branch, FI&P, Office of Chief Counsel, IRS
  • Megan McGuire, Attorney, Insurance Branch, FI&P, Office of Chief Counsel, IRS
  • Daniel Phillips, Senior Counsel, Insurance Branch, FI&P, Office of Chief Counsel, IRS
  • Kathryn Sneade, Senior Technician Reviewer, Insurance Branch, FI&P, Office of Chief Counsel, IRS
9:20-10:20 a.m.

Session 8A
Will the TCJA “Reform” Consolidated Returns?
This panel will discuss proposed and possible changes to consolidated return regulations in light of amendments by the Tax Cuts and Jobs Act of 2017. Specific provisions discussed will include: (i) section 163(j) and its application in a life/nonlife consolidated return, and (ii) section 172 and NOLs, the new 80% taxable income limitation, and the exception for property/casualty insurance companies. Any other relevant developments in the consolidated return regulations potentially affecting insurance companies will be discussed, including the possibility of general changes to life/nonlife regulations.

  • Lori J. Jones, Partner, Scribner Hall & Thompson, LLP (moderator)
  • Daniel Eppley, Vice President, Tax, Nationwide Mutual Insurance Company
  • Eli Katz, Managin Director, Deloitte Tax LLP
  • Justin Kellar, Assistant to Branch Chief, Branch 3, Corporate, Office of Chief Counsel, IRS
  • Christopher Schoen, Counsel, Eversheds Sutherland (US) LLP

Session 8B
Investments
This panel will provide a discussion of the latest developments on investment tax issues that affect insurance companies, with an emphasis on provisions in the Tax Reform and Jobs Act. It also will include a discussion of potential capital/ordinary reform.

  • Samuel Mitchell, Partner, Scribner Hall & Thompson, LLP (moderator)
  • Alan Fu, Vice President & Corporate Counsel, Prudential Financial, Inc.
  • Jeff Maddrey, Principal, PwC
  • Jonathan Zelnik, Principal, KPMG LLP 

Session 8C
A View from the Top: A Conversation with Tax Directors
A discussion with top Tax Directors on challenges and opportunities currently facing the industry.

  • Sarah Sheldon, Assistant Vice President & Assistant Tax Counsel, Metropolitan Life Insurance Company (moderator)
  • Melissa Hall, Senior Vice President, Global Head of Tax, Assurant, Inc.
  • Dina Shapiro, Chief Tax Officer, Marsh & McLennan Companies, Inc.
  • Joe Vaccaro, Senior Vice President & Global Tax Director, Metropolitan Life Insurance Company
10:40-11:40 a.m.

Session 9A
Ethics & Social Media

The intersection of privacy law and tax law presents many open issues in the social media space. Panelists will
discuss potentially relevant rules and issues, and provide tips on best practices.

  • Stacey Brandenburg, Shareholder, ZwillGen PLLC
  • Jonathan Errico, Manager, Deloitte Tax LLP

Session 9B
State and Local Tax: National Trends

This panel will discuss national trends impacting state and local tax. The topics will include: tax reform, the Wayfair
decision, legislative trends, and audit trends.

  • Christine Gustafson, Consultant, TriTech Software (moderator)
  • Sahang-Hee Hahn, Lead Counsel, State and Local Tax, Massachusetts Mutual Life Insurance Company
  • Fran O’Loughlin, Senior Manager, Multistate Tax, Deloitte Tax LLP
11:50 a.m.-12:30 p.m.

Takeaway Panel
This session will provide a forum for lingering questions, comments, and discussion of “top of mind” issues with some of the top minds in the industry!

  • Susan E. Seabrook, Partner, Eversheds Sutherland (US) LLP (moderator)
12:30 p.m. Boxed Lunch Available


 

This popular program has experienced a surge in registration and the room block at the JW Marriott has sold out. The hotel cannot accommodate additional rooms at our previously contracted discounted rate. Please find a list of nearby hotels for your stay in Washington, DC that are comparable in pricing.

Courtyard by Marriott Washington DC / Foggy Bottom
515 20th St NW, Washington, DC 20006
202-296-5700

Grand Hyatt Washington
1000 H St NW, Washington, DC 20001
202-582-1234

Hilton Garden Inn Washington DC
815 14th St NW, Washington, DC 20005
202-783-7800

Hampton Inn Washington DC / White House
1729 H St NW, Washington, DC 20006
202-296-1006

Hyatt Place Washington DC / White House
1522 K St NW, Washington, DC 20005
202-830-1900

Kimpton Hotel Monaco
700 F St NW, Washington, DC 20004
800-649-1202

Washington Marriott at Metro Center
775 12th St NW, Washington, DC 20005
202-737-2200




Premier Sponsors

Event Partner


Contact Elizabeth Johnson if you are interested in sponsoring this event.

If you have any questions regarding this program, please contact Caitlin Rider, Sr. Meeting Planner.
Date
May 30 - 31, 2019
Location
JW Marriott
1331 Pennsylvania Ave NW
Washington, DC 20004
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