With more than 100 tax lawyers worldwide, our Tax practice covers every aspect of corporate, partnership and individual taxation in the United States, Europe and Asia, including taxation of cross-border transactions and state and local issues. The team includes sub-practices in transactions, consulting and planning, audits, administrative appeals and litigation, and government relations. Our insurance tax practice represents insurers as well as reinsurers. Our work includes assisting with the organization and operation of offshore companies as non-CFCs and non-PFICs, drafting operating guidelines for non-US companies to follow so as not to be subject to US net income taxation, and addressing insurance industry-specific questions. We also advise clients with respect to various insurance and annuity products. In addition, we regularly represent many of the world’s largest banks in connection with complex financing transactions, as well as planning, securitization, financial products and investment fund practices.
Select insurance tax engagements by Mayer Brown partners include:
- Variable annuity transformers. We advised major banks on tax issues connected with variable annuity transformer transactions.
- Re-domestication. We have served as the principal outside US tax advisor to ACE Limited since 1987, including ACE Limited's re-domestication from the Cayman Islands to Switzerland.
- Expatriation and Bermuda startups. We serve as the US tax architect of the expatriation of Everest Re to Bermuda, and of the formation of several Bermuda startups, including LaSalle Re and Endurance Specialty.
- Offshore insurance companies. We advise Citadel and other fund managers on the formation of offshore insurance companies owned by hedge funds.
- Sidecars. We advised on several transactions involving the securitization of insurance risk, including securitizations for Radian Guaranty and MGIC, and tax issues relating to other sidecar transactions.
- American Express. We advised on the tax aspects of American Express's sale of its UK insurance group.
- Transfer pricing. We have provided transfer pricing advice for insurance and reinsurance companies including Assured Guaranty and Everest Re.