Wednesday, May 27, 2020
[12:45 p.m. – 1:00 p.m.] Opening Remarks

• Jean Baxley, Private Sector, Seminar Co-Chair
• Daniel J. Kusaila, Crowe LLP
• Alexis A. MacIvor, Public Sector, Seminar Co-Chair
• Surjya Mitra, Private Sector, Seminar Co-Chair

[1:00 p.m. – 2:30 p.m.] Update from the Insurance Branch

This 90-minute panel will include a discussion with several representatives of the Insurance Branch of the Financial Institution and Products division within the IRS Office of Chief Counsel.  Attendees 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.

• Lori Robbins, Managing Director, KPMG LLP (moderator)
• Rebecca L. Baxter, Senior Technician Reviewer, Insurance Branch, Office of the Associate Chief Counsel (FI&P), I.R.S.
• John E. Glover, Senior Counsel, Insurance Branch, Office of the Associate Chief Counsel (FI&P), I.R.S.
• Alexis A. MacIvor, Branch Chief, 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.

[3:00 p.m. – 4:30 p.m.] Insurance Company Tax Issues

The panel will discuss Federal income tax issues that were most impactful in the past year for life, property and casualty, and health insurers, including proposed regulations under section 807, changes in the determination of discounted unpaid losses, and generally-applicable developments that are especially important to insurers.  Issues arising under the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act) will be discussed on a different panel.

• Mark Smith, Managing Director, PwC (moderator)
• Pam Biesecker, Senior Vice President, Chief Tax Officer, Nationwide Mutual Insurance Company
• Daniel P. Phillips, Senior Counsel, Insurance Branch, Office of the Associate Chief Counsel (FI&P), I.R.S.
• Regina Rose, Senior Vice President, Taxes & Retirement Security, American Council of Life Insurers
• Fred von Rueden, Blue Cross Blue Shield Association
• Christopher W. Schoen, Counsel, Eversheds Sutherland LLP

Thursday, May 28, 2020
[1:00 p.m. – 2:30 p.m.] International Tax Issues

The international tax panel will provide an overview of the latest U.S. international tax developments relevant to global insurance and reinsurance companies. Panelists will discuss the tax implications of the Coronavirus Aid, Relief, and Economic Security (CARES) Act, including the interplay of the expanded net operating losses carryback provisions with the U.S. international tax rules (covering FTCs, the Section 250 deduction and GILTI).  The panel also will discuss the tax implications of COVID-19 travel restrictions and will examine recent U.S. tax legislative updates, including with respect to BEAT, PFICs, Section 954(i), and Section 807 reserves.

• Jason Kaplan, Principal, International Tax, Deloitte Tax LLP (moderator)
• Eric Lopata, Vice President, Corporate Counsel, Prudential Financial, Inc.
• Surjya Mitra, Managing Director, PwC
• Chris Ocasal, Principal, EY

[3:00 p.m. – 4:30 p.m.] Product Tax Update

The panel will discuss the recently enacted Setting Every Community Up For Retirement Enhancement Act (SECURE Act) and how the new provisions affect annuity contracts, with a particular focus on the new after-death distribution requirements in section 401(a)(9).  The panel will explore what changes might be needed to annuity contracts in order to comply with these new rules.  In addition, the panel will address the temporary retirement plan relief provided by the recently enacted Coronavirus Aid, Relief, and Economic Security (CARES Act).  The panel will also review some of the issues presented by the required minimum distribution rules under section 401(a)(9), including the application of the minimum income threshold test set forth in Treas. Reg. sec. 1.401(a)(9)-6 to certain types of annuity payment options.  The panel will discuss the final regulations relating to the new reportable policy sale rules in section 6050Y and the new transfer for value rules in section 101 and the issues they present for life insurance contracts.  Finally, the panel will review the new advisor fee private letter rulings for non-qualified annuity contracts under section 72 that were recently issued by the IRS.

• Alison R. Peak, Partner, Davis & Harman LLP (moderator)
• Graham R. Green, Counsel, Eversheds Sutherland LLP
• Mark Rush, Head of Product Tax Legal, MassMutual
• Tamara Saverine, Vice President, Corporate Counsel (Tax), Prudential Financial Inc.

Friday, May 29, 2020
[1:00 p.m. – 2:30 p.m.] The COVID-19 Pandemic: Relevant Tax Legislation and Other Considerations for Insurers

This panel will discuss corporate and individual tax provisions of the CARES Act and other coronavirus legislative proposals that impact the insurance industry. The panel will consider the impact of corporate tax provisions of the CARES Act, including, among other things, the new carryback rules and the changes to section 163(j). The panel will also discuss individual provisions of interest to the insurance industry, such as the retirement changes. Finally, the panel will consider pending law changes that may be included in future legislation.

• Ann Cammack, Principal, EY (moderator)
• Eric Solomon, Partner, Steptoe & Johnson LLP (moderator)
• Lori J. Jones, Partner, Scribner Hall & Thompson LLP
• Daniel Kusaila, Partner, Insurance Tax Practice, Crowe LLP
• James J. (Jim) Shea, Vice President, Chief Tax Officer, Prudential Financial Inc.

[3:00 p.m. – 4:30 p.m.] Multi-state Hot Topics

This panel will discuss current multi-state issues related to the TCJA, the CARES Act, Wayfair and economic nexus issues, COVID-19 compliance considerations, and indirect tax issues that impact the insurance industry.  The speakers will discuss state tax conformity and decoupling issues related to the TCJA and CARES Act including Sec. 163j business interest limitations, NOL treatment and other conformity issues.  The panel will also analyze income and other tax considerations regarding economic nexus that insurance industry companies and their advisors need to consider in the post-Wayfair tax environment.  The panel will also discuss the state tax compliance issues associated with COVID-19.  Finally, the panel will consider indirect tax issues that are significantly impacting the tax and business operations of insurance companies and their non-insurance related entities.

• Arthur “Art” Burkard, Managing Director, State and Local Tax Services, Grant Thornton LLP (moderator)
• Josie Lowman, Managing Director, Insurance State Tax Leader, PwC
• Brendon J. McKibbin, Partner, State & Local Tax, Deloitte Tax LLP

[4:30 p.m. – 4:45 p.m.] Closing Remarks