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[Virtual] Insurance Tax Seminar

May 27, 2021 - May 28, 2021

The FBA Section on Taxation offers another virtual seminar on topics of interest to the insurance industry. The seminar will continue its tradition of providing a forum for a robust dialogue between the insurance industry, tax practitioners and government sector professionals. The program will be held on May 27-28. Participants will have the opportunity to stay up-to-date on the latest tax developments and guidance by choosing from sixteen different panels. Seminar topics have been carefully curated to cover viewpoints on the latest insurance company, insurance product, international, and other relevant and timely insurance tax topics, such as the evolving tax function and potential for new tax law changes.

CLE and CPE Credit Available – Scroll for more information.

Registration for this event is now closed.


Agenda

Thursday, May 27

10:00 – 11:00 a.m. ET | Opening Session + Keynote Remarks

Keynote Speaker: Peter Phelan, President, Phelan Advisory LLC
Peter Phelan is the President of Phelan Advisory LLC, an independent firm offering bespoke advisory services to banks, asset managers, non-financial corporates, private equity firms, and capital markets businesses. Peter was most recently the Deputy Assistant Secretary for Capital Markets at the U.S. Department of the Treasury, ending his service in January 2021. As part of the Domestic Finance team, Peter advised the Secretary and other Department senior leadership on the policy implications and effects of all capital markets activities across the nation.

General Session Sponsored by BKD CPAs & Advisors

11:30 a.m. – 12:30 p.m. ET | Session 1

Prospects for Tax Changes in 2021-2022

President Biden has proposed sweeping infrastructure projects, offset in part by corporate, international, and individual tax increases.  This panel, featuring Congressional and Treasury staff, will give tax professionals an insight into the shape of and prospect for changes, so they can structure future operations taking the new rules into account.  Additionally, attendees will learn of counter proposals to the Biden tax plan. They will be prepared to modify foreign and domestic structures as necessary to comply with new requirements.  Finally, attendees will have a unique experience of Q&A with key stakeholders.

  • Moderator: Pamela Olson, Consultant, Tax Policy Services, PwC
  • Courtney Connell, Senior Tax Counsel, Senate Finance Committee (R)
  • Andrew Grossman, Chief Tax Counsel, House Ways and Means Committee (D)
  • Tiffany Smith, Chief Tax Counsel, Senate Finance Committee (D)
  • Derek Theurer, Chief Tax Counsel, House Ways and Means Committee (R)
  • Tom West, Deputy Assistant Secretary (Domestic Business Tax), U.S. Department of the Treasury

1:00 – 2:00 p.m. ET | Session 2A & 2B

2A: Life Insurance Tax Issues and Legislative Update

The panel will discuss the income tax issues that were most impactful to life insurers during the past year.  Topics will include reinsurance tax planning strategies, regulatory capital considerations, and the section 807(f) regulations.  The panel will further discuss potential legislation, including U.S. Tax Reform, OECD Pillar 2, and other significant legislative proposals.  The panel will discuss key planning ideas and considerations related to the proposed legislation.  Finally, the panel will discuss the IRS’ Tax Cuts and Jobs Act Campaign.

  • Moderator: Matthew T. Jones, Managing Director, Business Tax Services, KPMG LLP
  • Michael Beaty, Partner, Financial Services, EY
  • John E. Glover, Senior Counsel, Insurance Branch, Office of the Associate Chief Counsel (FI&P), IRS
  • Daniel Kheel, Vice President, Tax Planning & Strategy, MetLife
  • Matthew Lodes, Partner, PwC

2B: Hot Topics in Multistate Taxation

The panel will present and discuss relevant state and local tax areas of interest including the impact of remote workers in today’s work from home environment, recent legislative policies and developments as well as current topics facing state and local tax departments.

  • Moderator: Brendon McKibbin, Partner, Multistate Tax, Deloitte Tax LLP
  • Abbie Foreman, Senior Manager, State & Local Tax, EY
  • Tov Haueisen, Partner, State & Local Tax, PwC
  •  Gerardo (Jerry) Malanga, Corporate Vice President, New York Life

2:30 – 3:30 p.m. ET | Session 3A & 3B

3A: Life Reserves Potpourri

This panel will focus on recent guidance relevant to the computation of life insurance reserves.  Panelists will discuss the content, emerging issues, and application of post-TCJA reserves guidance including the section 807 final regulations and the recent section 807(f) “change in basis” revenue ruling.  The panel also will address practical issues that arise when applying the change in basis rules. The discussion will include an overview of relevant NAIC guidance, and cover any updates regarding activity on the two active section 807 LB&I campaigns.  Participants will gain an understanding of the post-TCJA life reserves guidance, and be able to identify and address practical issues that are encountered in applying IRS and NAIC life reserves guidance in tandem.

  • Moderator: Jean Baxley, Managing Director, Deloitte Tax LLP
  • Richard Bush, Senior Vice President, Ameriprise
  • Kristin Norberg, Vice President, Tax, Symetra
  • Daniel P. Phillips, Senior Counsel, Insurance Branch, Office of the Associate Chief Counsel (FI&P), I.R.S.
  • Mark Smith, Managing Director, PwC
  • Jeff Stabach, Tax Actuarial Manager, EY

3B: Capital Planning & Investments

A discussion of current trends and motivations of new capital providers to the insurance sector and existing insurers.  The insurance industry has seen many new entrants in recent years, reinsurers have adapted to the needs of the market and new tax regimes and have modified their offerings beyond traditional product offerings.  Insurers have expanded their investment universe.  What is motivating these changes?  How are these changes impacting the market? What is attracting new investors to the insurance sector? What analysis are insurers doing to select between investment opportunities?

  • Moderator: Wesley Reynolds, Principal, PwC
  • Pete Edgerton, Partner, Sidley Austin LLP
  • Kevin Hovi, President & Chief Financial Officer, Kuvare Life Re Ltd.
  • Ritendra Roy, Managing Director, Oppenheimer

4:00 – 5:00 p.m. ET | Session 4A & 4B

4A: P&C Company Tax

This panel will discuss an overview of recent income tax issues that impact property and casualty companies, including the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), domestic provisions of Made in America Tax Plan, regulations for consolidated net operating losses (CNOLs), SSAP 101 developments, IRS Large Business and International (LB&I) Campaigns overview, and state tax development impacting P&C companies.

  • Moderator: Timothy Peacock, Partner, PwC
  • Ruth Kelly, Technical Advisor, IRS LB&I Enterprise Practice Area
  • Daniel Kusaila, Partner, Crowe LLP
  • Sarah Pisacich, Managing Director, KPMG

4B: The Evolving Tax Function

Panelists will draw upon their vast and diverse experiences to share insights into the evolving tax function.  The panel will cover a wide range of topics with an emphasis on the future of tax work in a post pandemic world.  Specific areas addressed will include future staffing models;  talent identification, recruitment, and retention;  training, technology, operating models, developing and mentoring employees;  and maintaining culture.  The panel will also address the looming shortage of tax professionals and the ever increasing pace and volume of legislative activity.  Attendees will obtain valuable insights which will provide opportunities to optimize their future tax function.

  • Moderator: Scott W. Rynda, SVP, Travelers
  • Chris Albert, Partner, Deloitte Tax LLP
  • Anne Farrar, Partner, Financial Services Tax, EY
  • Jim Shea, SVP & Chief Tax Officer, Prudential
  • Joe Tedesco, SVP & Global Head of Tax, AXA XL

Friday, May 28

10:00 – 11:00 a.m. ET | Update from the Insurance Branch

This panel features a discussion with several representatives of the Insurance Branch of the Financial Institution and Products Division within the IRS Office of Chief Counsel.  The audience will hear Insurance Branch personnel describe recent tax guidance and significant rulings issued by the Branch within the past year as well as current projects being considered by the Branch.  The panel will include a discussion of final regulations issued under IRC section 807 that provide guidance on the computation of life insurance reserves and the change in basis of computing certain reserves of insurance companies.  The panel will increase the professional competence and skills of the audience in the representation of taxpayers on U.S. federal income tax issues.  A primary learning objective is to give attendees an understanding of the role and responsibilities of the Branch as well as an understanding of how to apply the final regulations under IRC section 807.

  • Moderator: Graham R. Green, Counsel, Eversheds Sutherland LLP
  • Rebecca Baxter, Acting Branch Chief, Insurance Branch, Office of the Associate Chief Counsel (FI&P), I.R.S.
  • Ian Follansbee, Attorney Advisor, Insurance Branch, Office of the Associate Chief Counsel (FI&P), I.R.S.
  • Beth Hill, Attorney Advisor, Insurance Branch, Office of the Associate Chief Counsel (FI&P), I.R.S.
  • Megan McGuire, Attorney Advisor, Insurance Branch, Office of the Associate Chief Counsel (FI&P), I.R.S.
  • Daniel P. Phillips, Senior Counsel, Insurance Branch, Office of the Associate Chief Counsel (FI&P), I.R.S.
  • Kathryn M. Sneade, Senior Technician Reviewer, Insurance Branch, Office of the Associate Chief Counsel (FI&P), I.R.S.

11:30 a.m. – 12:30 p.m. ET | Session 5A & 5B

5A: Product Tax Update

This panel will focus on recent product tax developments.  Among other things, the panelists will cover the CAA changes to section 7702, including discussion of the technical changes, as well as the practicalities involved in implementing them.  The session will also focus on changes that the SECURE Act made to the post-death RMD rules applicable to qualified plans and IRAs and delve into interpretative questions that remain to be addressed.  The panelists will also provide commentary on recent court rulings and administrative guidance involving life insurance, annuities and pension plan contracts; e.g., nonqualified annuities issued to trusts, split-dollar life insurance, fee-based annuities and investor control.

  • Moderator: Frederic J. (Rick) Gelfond, Principal, Tax, EY
  • Robert Fishbein, Vice President & Corporate Counsel, Prudential
  • Bryan Keene, Partner, Davis & Harman
  • Kim Lunn, Assistant General Counsel & Assistant Secretary, Northwestern Mutual
  • Stephen B. Tackney, Deputy Associate Chief Counsel (EEE), IRS

5B: A Discussion of Current Topics Related to BEAT, PFIC, and OECD Initiatives

This panel will discuss topics related to BEAT, PFIC, and OECD tax initiatives, in particular Pillar Two.  The panel also will discuss current Biden administration and Congressional proposals related to these topics. Presenters will explain the current BEAT rules and the proposals for revising or replacing those rules. The panel will examine the final and proposed PFIC regulations and the comments addressing those regulations. Lastly, discussion will explore OECD Pillar Two and how it could impact insurance companies.

  • Moderator: M. Kristan Rizzolo, Partner, Eversheds Sutherland LLP
  • Jason Kaplan, Principal, Deloitte Tax LLP
  • Surjya Mitra, Managing Director, PwC
  • Joy Tegtmeyer, SVP, Head of Group Tax, Renaissance Re
  • Angela J. Walitt, Attorney-Advisor, Office of Tax Policy, U.S. Department of the Treasury

1:00 – 2:00 p.m. ET | Session 6A & 6B

6A: Information Reporting and Withholding

This panel will discuss the dramatic changes being proposed to the withholding regimes for periodic and non-periodic payments, the open reporting and withholding issues with respect to amounts escheated to state unclaimed property funds, industry issues concerning the deposit of withheld taxes, and international issues relating to FATCA, the EU’s Mandatory Disclosure Regime, Luxembourg’s new register of actions requirement, and payments made outside the US.

  • Moderator: Mark E. Griffin, Partner, Davis & Harman
  • Anthony Calabrese, Managing Director, EY
  • Erin Campbell, Manager, Global Information Reporting, Deloitte Tax LLP
  • Sarah Lashley, Assistant General Counsel, Transamerica
  • Mat Momen, Vice President & Associate General Counsel, Metlife
  • Stephen B. Tackney, Deputy Associate Chief Counsel (EEE), I.R.S.

6B: Current Outbound Insurance Issues: A Practical Illustration

This panel will explore, in a case study format, the current, proposed, and possible future considerations with respect to outbound insurance issues in the US federal tax context. The panel will focus on the interaction of Subpart F, GILTI, related person insurance income, section 954(i) and foreign tax credits both in today’s environment and under various legislative proposals put forth in the past few months. The panel will also explore considerations around section 953(d) companies and the dual consolidated loss regime.

  • Moderator: Chris Ocasal, Principal, EY
  • Paul Aronoff, Vice President & Tax Counsel, Prudential
  • Janet Glendening, VP – International Tax, RGA
  • John Owsley, EY
  • Elena Raffensperger, SVP & Senior Director – International Taxation, Liberty Mutual
  • Chris Riffle, Director, PwC
  • Angela J. Walitt, Attorney-Advisor, Office of Tax Policy, U.S. Department of the Treasury

2:30 – 3:30 p.m. ET | Session 7A & 7B

7A: Talkin’ ’Bout Consolidation – An Update on Consolidated Return Issues Impacting Insurance Companies

The purpose of this panel is to discuss current consolidated return issues affecting both life and nonlife insurance companies.  Panelists will provide an overview of recently completed IRS regulatory projects addressing consolidated return matters, including the final regulations applying the net operating loss (NOL) provisions, as amended by the Tax Cuts and Jobs Act and the CARES Act, to consolidated groups, with a focus on the special rules applicable to nonlife insurance companies.  The panel also will discuss the latest developments involving the life/nonlife consolidated return regulations and what may be on the horizon for those regulations.  Moreover, the panelists will provide a brief review of other ongoing consolidated return projects at the IRS that may affect insurance companies in certain instances.  Panelists will share their insights on these topics, along with practice pointers.

  • Moderator: Lori Jones, Partner, Scribner Hall & Thompson LLP
  • Will Burhop, Senior Technician, Branch 5, Office of Chief Counsel (CORP), I.R.S.
  • William Pauls, Principal, Deloitte Tax LLP
  • Frederick Peurye, Vice President – Taxation, Empower
  • Anna Rubinstein, Tax Director, AIG

7B: Health Company Tax

This panel will discuss tax issues that were most impactful in the past year for health insurers.  Topics covered will include significant judicial developments, regulations under section 162(f) as applied to the health insurance industry, and developments with respect to risk corridor payments.  The panel also plans to discuss the applicability of section 165(i) to COVID-related losses.  In addition, the panel will highlight certain health-related compensation and benefits developments, including any potential legislative proposals involving COBRA and other similar health benefits.  Finally, panelists will address some state tax proposals and recently enacted state tax laws directly affecting health insurers.

  • Moderator: Lori A. Robbins, Managing Director, KPMG LLP
  • Daniel P. Bartholet, Vice President – State Taxes, UnitedHealth Group
  • Mark Halpin, Managing Director, KPMG LLP
  • Chad A. Hamann, Vice President – Tax, UnitedHealth Group
  • Jason Stern, Tax Partner, Deloitte Tax LLP
  • Fred von Rueden, Executive Director, Plan Tax and Financial Regulatory Services, Blue Cross Blue Shield Association

4:00 – 5:00 p.m. ET | Session 8A & 8B

8A: Ethics, Diversity, and Inclusion in Tax and the Tax Department

Diversity and inclusion is increasingly an area of focus in companies, the legal community, and the government.  Attendees will be informed about current developments relating to ethics, diversity, and inclusion and how they relate to the tax law, the practice of law, and business.  In this session, we will discuss:

  • Why diversity and inclusion is an area of significant attention;
  • How diversity and elimination of discrimination is being addressed in legal ethics rules;
  • Developments and statistics relating to diversity in law, tax, and companies;
  • What workplaces are doing to address diversity and inclusion.
    • Moderator: Amanda Varma, Partner, Steptoe & Johnson LLP
    • Marcia Persaud, Associate General Counsel, New York Life Insurance Company

8B: Reinsurance Basics Panel

An introduction to reinsurance transactions. This presentation will introduce basic definitional concepts, including the purposes and forms of reinsurance used by P&C and life and annuity companies. We will also discuss the tax requirements of reinsurance, and the tax consequences of various forms of reinsurance transaction, including in relation to applicable statutory and financial accounting rules.

  • Moderator: Peter Schuur, Partner, Debevoise & Plimpton LLP
  • Edward Clabault, Senior Tax Manager, EY
  • Todd Doyle, VP & Tax Counsel, Nassau Re
  • Rob Finnegan, PwC

*Subject to Panelist Confirmation


Registration

Registration is now closed for this event.
Attendees will receive access information via welcome email and panel calendar invitations on Monday, May 24.

Live Captioning: Closed captioning is available for all virtual webcasts.

Cancellation Policy: No refunds will be made for cancellations received after the close of business on Friday, May 21. Please contact Ariel White at awhite@fedbar.org with cancellation and/or substitution requests.

Internet Requirements: Virtual Conferences require suitable internet strength to stream online panels. A minimum internet connection of 800 Kbps is recommended for an optimal attendee experience. Test your connection here


CLE / CPE Updates

CLE CREDIT

Attendees can receive up to 9 CLE credits (10.8 credits for 50-min states).

CLE Credit will be processed/reported approximately 4-6 weeks after the event date and available for credit in states that allow credit for live webinar presentations. You must attend the live broadcast, answer engagement polls, and accurately enter your bar number in our database to receive credit. Certificates and required documentation for self-reporting states will be issued via email, upon state bar approval. Thank you in advance for your patience, as state bars are experiencing significant delays with virtual program processing.

Click Here for more information on CLE Attendance and Reporting.

CPE SPONSOR

The Federal Bar Association is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors maybe submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org. For more information regarding administrative policies such as refunds, cancellations and complaints, please contact the Federal Bar Association at 571-481-9100. Prerequisite: None; Program Level: Basic; Advanced Prep: None;
Field of Study: Taxes; Delivery Method: Group Live delivered online due to COVID-19; Credit Hours: 10.8.

To qualify for CPE Credit, attendees must attend the panel’s live broadcast, answer all pop-up engagement polls, and accurately enter his/her information into each panel’s entry form. Certificates will be issued approximately 4-6 weeks after the event date.


Sponsors

PREMIER SPONSOR

EVENT PARTNER

BKD CPA’s & Advisors

Email sponsor@fedbar.org if you’re interested in sponsoring this event. View our Virtual Sponsorship Prospectus for current offerings.


Frequently Asked Questions

Q: What type of educational credit will be offered in the virtual format?
A: Attendees can receive up to 8 CLE credits (9.6 credits for 50-min states). Please check with your respective state(s) for distance learning CLE requirements. CPE Credit has been approved for this event.

Q: How do I obtain CLE Credit?
A: All registrants will be prompted to submit state bar information prior to the virtual series to ensure accurate CLE reporting. Credits will be processed/reported within 4-6 weeks of the webinar event date and available for credit in states that allow credit for live webinar presentations. Your bar number must be accurate in our database to receive credit. We will share detailed instructions with registrants for CLE reporting.

Q: How do I access the virtual panels?
A: Virtual panels will each have a unique link to watch the live broadcast. Registered attendees will receive login instructions via a welcome email and calendar invitations the week of the conference.

Q: Will recordings of the sessions be available after the event?
A: Sessions will be available for registrants to view live and on-demand following the conference. Please note that CLE credit will only be submitted for attendees that watch the live broadcast.

Q: Who do I contact for more information?
A: Please contact meetings@fedbar.org for any other questions.


Email Communication Policy
By registering for this event, you agree to receive email communications from the Federal Bar Association and affiliated sponsors of the program concerning event details, Continuing Legal Education certification, programming changes, upcoming events, surveys, and post-event communications.

Recording Disclaimer
By registering for an online FBA program, you agree to the recording of audio and visual content presented during the live event and consent to subsequent use of the recording by the FBA. You agree that the recording is the sole property of the FBA and that the recording may be used by the FBA in any manner in its sole and absolute discretion. This recording may include questions and poll responses provided by you during the live event. If you do not consent to the recording and the FBA’s use of the same, do not register for the event.

Financial Assistance
Program registrants (both FBA members and nonmembers) who are unable to afford the registration fee may receive a 50% discount on the member rate. Qualifying attorneys include those who are unemployed or actively seeking employment. A formal letter requesting the discount must be emailed to meetings@fedbar.org. That letter needs to state the reason for the attorney’s interest in the course or activity, as well as proof of income or an explanation of the financial hardship, and it must be signed by the requesting lawyer.

Details

Start:
May 27, 2021
End:
May 28, 2021
Event Category:

Venue

Online
US