Taxation

Foley Insurance attorneys provide our insurance and reinsurance clients with comprehensive counsel relating to audits, administrative appeals, and litigation involving contested insurance tax matters at both the federal and state levels.
We provide counsel to insurers and reinsurers in the property/casualty and life and health sectors, insurance industry trade associations, brokers and intermediaries, and state regulators. We also represent captive insurers, banks, utilities, national retailers, steel and manufacturing companies, not-for-profit organizations, accounting firms, banks, and other law firms that retain us to assist with insurance tax issues.
Our services include planning for and structuring mergers and acquisitions, leases, dispositions, executive compensation, and other tax-sensitive transactions. We also will represent you in audits, administrative appeals, and litigation involving contested insurance tax matters at both the federal and state levels. With our considerable experience representing clients before Congress, the U.S. Department of the Treasury (Treasury Department), and state legislatures, we are substantially involved in the development of legislation and regulations at the state and federal levels.

Representative Matters

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Represented a large international life insurance company in a premium tax audit by the Wisconsin Office of the Commissioner of Insurance and successfully negotiated a favorable settlement of the insurer's tax liability.
Complex tax planning project for regional health insurance company in receivership that received large litigation recovery in 2011.
Represent a major multistate professional liability insurance company in an IRS audit, in which the main issue is whether the company's unpaid loss reserve is "fair and reasonable." Potential $300 million adjustment to income.