Foley & Lardner LLP

Insurance Taxation

Foley Insurance & Reinsurance Industry Team 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.

Administrative, Legislative, and Regulatory Tax Experience
We are prepared to assist and represent you before the IRS — during audits, administrative appeals, and at the National Office of the IRS. We also can help with unpaid loss reserve deductions that have been challenged by the IRS and obtain legislative and regulatory relief on tax matters pending before Congress and the Treasury Department. We are currently representing cases in audit and at the IRS appellate level involving nearly $1 billion in proposed adjustments.

Since 1955, we have represented insurance companies and associations before Congress on virtually all major income tax legislation. We also represent insurance company clients like you in all areas of state taxation, with a particular focus on state premium taxes and assessments.

Thought Leadership You Can Count On
We have served as chairs of the ABA Tax Section Committee on Insurance Companies, and participate on the advisory boards for The Insurance Tax Review, the Insurance Tax Conference (ITC), and ITC State Insurance Tax Conference. We also have represented the five major property/casualty trade associations on the IRS’s Information Reporting Program Advisory Committee.