Times posted in Eastern Time (ET) and are subject to change.
7:30 AM – 8:30 AM | Registration & Breakfast
8:30 AM – 9:30 AM | 1) Tax Legislative Outlook
A look at the Insurance Tax Legislative Landscape: This bipartisan panel will consist of leading Capitol Hill tax staff who will discuss the outlook for insurance tax issues and what stakeholders need to be watching. Speakers will discuss not just emerging tax issues in the insurance marketplace, but also provide insights into the future of U.S. tax policy and the outlook for the legislative landscape.
Moderator Mark Roman, Principal, Deloitte Tax LLP
Speakers
9:40 AM – 10:40 AM | 2A) Life Insurance Company Tax Items of Interest
This panel will provide an update on key tax developments relevant to life insurance companies. Discussion topics will include implementation of VM-22 and GOES, evolving guidance on various reinsurance issues, including coinsurance and yearly renewable term reinsurance emerging from NAIC Statutory Accounting Principles Working Group, and reserve issues for 953(d) companies.
Moderator Jean M. Baxley, Tax Managing Director, Deloitte Tax LLP
Speakers
9:40 AM – 10:40 AM | 2B) International Tax Issues of Important to the Insurance Industry – Inbound
This panel will explore the latest international tax developments impacting inbound insurance groups. The panel will focus on the latest Pillar 2 OECD guidance as well as the most recent considerations for insurers and reinsurers within the Bermuda Corporate Income Tax (CIT). The panel will also explore the latest developments in the CAMT, US trade or business rules, and relevant tax law changes from OBBB for inbound insurers. Finally, the panel will provider an overview on the Lloyd’s of London market and the related US federal tax considerations as well as the latest in the affiliate reinsurance and third-party capital structure arenas. Note, this panel will focus on current issues and market developments as opposed to providing a primer on inbound topics. Participants will be able to understand the latest developments for inbound companies from a US federal tax perspective as well as popular and emerging structures for inbound insurers, reinsurers, and investors in insurance and reinsurance platforms.
Moderator Matthew Dubin, Senior Manager, Ernst & Young U.S. LLP
Speakers
9:40 AM – 10:40 AM | 2C) Primer: Structured Settlements
This panel will present an overview of structured settlements. The session will cover “qualified” and “nonqualified” structured settlements, structured attorney fees, the assignment of settlement payments to an assignment company, the use of annuity contracts to fund the settlement payments, the factoring (or acceleration) of structured settlement payments, and the use of designated settlement funds to hold and distribute settlement proceeds.
Moderator Mark Griffin, Partner, Davis and Harman LLP
Speakers
10:40 AM – 11:00 AM | Morning Break
11:00 AM – 12:00 PM | 3A) Current Outbound Insurance Issues
The panel will discuss cross-border, outbound areas of interest for insurance companies, highlighting audit trends, treaty interpretation issues, and compliance issues for insurance companies that have non-US operations. Specifically, the panelists will discuss recently issued guidance, including latest GLAMs relevant to insurance companies executing outbound transactions. The session will also cover practical challenges with IRC §953(d) election process, including closing agreement timing, treaty benefit considerations, and Form 8858 filing obligations. The panelists will examine key CFC issues affecting insurance groups, such as IRC §958(b)(4) implications, IRC §951B, and audit focus areas involving IRC §954(i). Finally, the panel will address current Foreign Excise Tax (FET) issues involving audit, payment timing, possible regulations, and treatment of funds withheld arrangements. Lastly, this session will provide an update on OECD Pillar Two side-by-side agreement, including implementation, required filings, GAAR regulations, structural opportunities, and overlap considerations.
Moderator Christopher James, Principal, Deloitte Tax LLP
Speakers
11:00 AM – 12:00 PM | 3B) P&C Company Tax Discussion
This panel will be a discussion about current issues of importance to property and casualty (P&C) insurance companies. The panel will cover the changes made in OBBB that are most relevant to P&C insurance companies. The group also will recent IRS processing and administrative issues that are impacting P&C companies. The panel will provide an update on captive tax issues, including recent court cases. Lastly, the presentation will also provide an update on tax credit considerations.
Moderator Sarah Pisacich, Partner, KPMG LLP
Speakers
12:00 PM – 1:30 PM | Keynote Luncheon
Kenneth Kies, Assistant Secretary for Tax Policy, U.S. Department of the Treasury
1:30 PM – 2:30 PM | 4A) Corporate Alternative Minimum Tax (CAMT) – Guidance Update for Insurance Companies
This panel will cover recent CAMT guidance developments and the expected timing and content of future CAMT regulations. More specifically, the panel will cover (1) key provisions from Notice 2025-27, Notice 2025-28, Notice 2025-46, Notice 2025-49, and Notice 2026-7 that are relevant to taxpayers in the insurance industry, (2) considerations for relying on the existing proposed CAMT regulations and the recent CAMT notices, and (3) expectations regarding the future proposed and final CAMT regulations.
Moderator Timothy Powell, Partner, Ernst & Young U.S. LLP
Speakers
1:30 PM – 2:30 PM | 4B) Investment Taxation Trends
This panel will provide an overview of current investment tax issues. We will review the investment market with a tax perspective in mind, including the outlook for insurance companies in a rising interest-rate environment. We will also review case law, regulatory and IRS guidance developments that could impact insurance company investments. There will also be a discussion of private and alternative investments with a particular focus on legal and regulatory developments for the taxation of credit investments, investment hedging and structured finance.
Moderator Daniel Winnick, Principal, KPMG LLP
Speakers
2:40 PM – 3:40 PM | 5A) OECD Developments Relevant to Multinational Insurance Groups
The panel will discuss Pillar Two developments that are relevant to inbound and outbound insurance groups. The panel will provide an overview of the Side-by-Side package released on January 5, 2026, and other recent OECD guidance. The panel will discuss what the recent Administrative Guidance means for insurance groups and what’s coming next as it relates to Pillar Two. Additionally, the panel will cover recent tax developments in Bermuda.
Moderator Peter Sproul, Partner, PwC U.S. Tax LLP
Speakers
2:40 PM – 3:40 PM | 5B) Tax Issues for Health Insurance Companies and Products
This panel will provide an update on recent developments and items of interest to health insurance companies. Discussion topics will include changes in OBBB that are most relevant to health insurance companies, recent Medicare pricing announcements, considerations relevant to provider support arrangements, RBC planning considerations, and other recent industry trends impacting health insurance companies.
Moderator Lisandra Ortiz, Member, Miller & Chevalier Chartered
Speakers
2:40 PM – 3:40 PM | 5C) Product Tax Update
This panel will discuss developments involving the federal income taxation of annuity and life insurance products, including updates related issues under the SECURE Act, SECURE 2.0 Act, One Big Beautiful Bill Act, required minimum distribution regulations, and guidance from the IRS and Treasury Department.
Moderator Alison Peak, Partner, Davis & Harman LLP
Speakers
3:40 PM – 4:00 PM | Afternoon Break
4:00 PM – 5:00 PM | 6A) Trending Tax Considerations in the M&A Marketplace
The M&A panel will cover a variety of developments in the M&A space. Among other topics, the discussion will cover special structuring and transactions involving Lloyd’s syndicates, including the new “London Bridge 2” structure. Panelists will discuss the role of both Rep and Warranty Insurance and tax insurance in M&A deals, including common pitfalls. A discussion of public M&A transactions will highlight key tax issues, structures and differences from private deals. The panel will also include a discussion of developments in the sidecar arena and other key changes in the M&A landscape.
Moderator Daniel Priest, Partner, Debvoise & Plimpton LLP
Speakers
4:00 PM – 5:00 PM | 6B) Key Developments in Tax Controversy
This panel will discuss current developments and topics of immediate interest in tax controversy and administrative practice. The panel will focus on court decisions, current legislative efforts impacting tax law, and other items relevant to tax administration.
Moderator Samuel Lapin, Member, Miller & Chevalier Chartered
Speakers
4:00 PM – 5:00 PM | 6C) Information Reporting and Withholding on Insurance Products
This panel will discuss developments concerning reporting and withholding issues affecting insurance products. This session will cover issues experienced in practice by insurers, as well as issues raised in connection with changes in the tax law made by the SECURE Act, SECURE 2.0 Act, and One Big Beautiful Bill Act.
Moderator Bryan Keene, Partner, Davis & Harman LLP
Speakers
5:00 PM – 6:30 PM | Reception
Sponsored by Crowe LLP
8:30 AM – 9:10 AM | Branch Update
Speakers
9:20 AM – 10:20 AM | 7A) OBBBA Provisions of Interest to the Insurance Industry
The One Big Beautiful Bill Act (OBBBA) was signed into law on July 4, 2025. Although the bill did not include any targeted insurance industry provisions, there are a variety of generally applicable changes that will impact health, life and property and casualty insurance companies, their investments and their products. This panel will explore the opportunities and challenges resulting from these changes. The panel will also consider what proposals were considered but not ultimately included in OBBBA. Finally, the panel will preview insurance industry proposals that may be considered in future legislation.
Moderator Marc J. Gerson, Attorney, Miller & Chevalier
Speakers
9:20 AM – 10:20 AM | 7B) History of Life Insurance Companies and Products Taxation
This panel will provide an overview of the historical taxing regimes for life insurance companies and products, from the inception of the income tax to the present day. Panelists will discuss the major milestones of life insurance taxation from an insurer and product perspective, including the underlying policy and economic drivers that motivated each change, and provide a perspective on what might come next.
Moderator William Waterson, Manager, Ernst & Young U.S. LLP
Speakers
9:20 AM – 10:20 AM | 7C) Navigating the Shifting State Tax Landscape: Risks and Opportunities for the Insurance Industry
The Multistate Tax Panel will examine the rapidly evolving state tax landscape and the mounting fiscal and policy pressures shaping state enforcement and legislative priorities. As states confront budget constraints and shifting federal policy, the resulting responses are creating both risk and opportunity for the insurance industry from a state tax perspective. Panelists will address the implications of the failure to reimpose ACA subsidies, the potential expansion of sales tax to services, and the impact of relocations and restructurings. The discussion will also explore state tax considerations in M&A, intercompany and unitary transfer pricing issues, OB3 conformity, and conclude with a practical state tax update highlighting significant recent developments and trends.
Moderator Daniel Kusaila, Partner, Crowe LLP
Speakers
Andy Koutroumanis, State Tax Director, Grant Thornton LLP
10:20 AM – 10:40 AM | Morning Break
10:40 AM – 11:40 AM | 8A) Primer: Life/Non-life Consolidated Returns
The panel will provide a detailed overview of the operating rules for life company and nonlife company consolidation under Treas. Reg. §1.1502-47. The overview will include basic definitions and concepts, eligibility requirements, five year waiting periods, tacking rules, the subgroup method and ordinary and capital loss utilization. The panel will also analyze a few recent private letter rulings to underscore key concepts. Additionally, a selection of related topics would be discussed in relation to these operating rules, such as entities entering or exiting a group, Section 250 Deductions, BEAT, CAMT and ordinary course transactions.
Moderator Surjya Mitra, Managing Director, PwC U.S. Tax LLP
Speakers
10:40 AM – 11:40 AM | 8B) Ethics: AI
Generative AI dominates the headlines, both positively and negatively. While AI offers significant opportunities to enhance efficiency and insight, its rapid adoption raises important ethical and professional responsibility questions for tax professionals. This panel will examine how core professional obligations, including competence, confidentiality, supervision, candor, documentation, and professional skepticism, apply when attorneys, CPAs, and other tax professionals rely on AI for research, drafting, due diligence, risk assessment, and communications. Panelists will discuss real-world scenarios involving the use of AI in analyzing complex tax positions and preparing communications, with an emphasis on how professionals remain accountable for the work product. In addition to discussing emerging legal and regulatory guidance, the panel will address practical implementation challenges within corporate tax departments and accounting and law firms, including governance, review standards, training, and talent development. Speakers will consider how organizations can responsibly integrate AI without eroding professional judgment, trust, and the development of future tax professionals.
Moderator Caitlin Tharp, Partner, Steptoe LLP
Speakers
10:40 AM – 11:40 AM | 8C) Tax Department Reimagined – AI Impact
Artificial intelligence is reshaping how insurance enterprises approach tax compliance, planning, and reporting — moving rapidly from proof-of-concept to production deployment. This panel brings together tax leaders from major carriers, reinsurers, and professional services firms to examine where AI delivers real results, and where challenges of data readiness, governance, and workforce transformation remain.
Moderator Jeff Webb, Partner, Deloitte Tax LLP
Speakers
11:50 AM – 12:30 PM | Ask the Experts
Not Available for CLE/CPE Credit.
Moderator Alexis A. MacIvor, Principal, PwC U.S. Tax LLP
Speakers
The FBA will seek 8.0 General CLE credit hours (including 1.0 ethics) in 60-minute states, and 9.6 General CLE credit hours (including 1.2 ethics) in 50-minute states.
Posted credit hours are estimates and subject to respective state approval and reporting rules. CLE qualifications vary by state/jurisdiction and the FBA takes every measure to collaborate with presenters to ensure approval. Accrediting agencies typically decide whether a program qualifies for credit in their jurisdiction 4-8 weeks after the program application is submitted. For many live events, credit approval is not received prior to the program. Documentation for self-reporting states will be issued via email, upon state bar approval.
The FBA partners with ConferenceAdit LLC to track and report CLE credit for national conferences. Attendees are responsible for uploading their state bar information and tracking attendance through a dedicated webpage, issued in advance of the conference. Attendees will be instructed to check in and out of each panel to timestamp attendance. Approximately two weeks following the conference, personalized certificates will be issued via email.
Learn more about Continuing Legal Education (CLE) operations and reporting.
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 may be submitted to the National Registry of CPE Sponsors through its web site: www.nasbaregistry.org.
Instructional Delivery Method: Group Live; CPE Credit Hours: 9.6; Field of Study: Taxes; Prerequisite: None; Program Knowledge Level: Beginner; Advance Preparation: None.