Times posted in Eastern Time (ET) and are subject to change.

Thursday, May 28

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.

Learning Objectives:

• Recent U.S. tax code policy changes impacting the Insurance industry, the reasoning behind those changes, and the potential for future tax code modifications with direct impact to the Insurance industry.
• Emerging U.S. tax code policy changes at large and tax issues expected to be debated before Congress with potential impacts to the Insurance sector.
• The impact these U.S. tax code policies could have on both individual and corporate taxpayers as well as the larger economy.

Moderator Mark Roman, Principal, Deloitte Tax LLP

Speakers

• Michael Gould, Tax Counsel, Senate Finance Committee (Majority)

• Larry Pounders, Tax Counsel, United States House Committee on Ways and Means (Majority)

• Ji Prichard, Tax Counsel, House Ways and Means Committee (Minority)

• Sarah Schaefer, Chief Tax Advisor, Senate Finance Committee (Minority

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.

Learning Objectives: 

• Understand current NAIC reserving updates and resulting tax-reserve, changes in basis, and STAT cap considerations. 
• Outline reserves related issues and considerations applicable to section 953(d) life insurance companies. 
• Understand additional recent developments applicable to life insurance companies. 

Moderator Jean M. Baxley, Tax Managing Director, Deloitte Tax LLP

Speakers

• Graham Cahill, Lead Counsel, Massachusetts Mutual Life Insurance Company

• Alexis A. Maclvor, Partner, PwC U.S. Tax LLP

• Daniel Phillips, Senior Counsel, IRS Office of Chief Counsel

• Regina Y. Rose, Senior Vice President, Tax Policy, American Council of Life Insurers (ACLI)

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.

Learning Objectives: 

• 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. 
• Participants will be able to understand the latest developments the latest developments in the CAMT, US trade or business rules, and relevant tax law changes from OBBB for inbound insurers.
• Participants will be able to understand the latest developments in Pillar 2 OECD guidance as well as the most recent considerations for insurers and reinsurers within the Bermuda Corporate Income Tax (CIT) .

Moderator Matthew Dubin, Senior Manager, Ernst & Young U.S. LLP

Speakers

• Anthony Calabrese, Managing Director, KPMG LLP
• Jonathan Galin, Attorney-Advisor, U.S. Department of Treasury
• Jason Kaplan, Principal, Deloitte Tax LLP
• Christopher Riffle, Principal, PwC U.S. Tax LLP

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.

Learning Objectives: 

• The structure, federal income tax requirements, and federal income tax treatment of (1) “qualified” structured settlements under which the payments are excludable from gross income, and (2) “nonqualified” structured settlements which might or might not be excludable from gross income depending on the facts and circumstances. 
• The treatment of attorney fees that are paid out of the settlement proceeds. 
• The role of an assignment company to which the liability to make structured settlement payments may be assigned, and the treatment of such an assignment under IRC section 130 in the case of a qualified structured settlement. 
• The use of annuity contracts to fund the structured settlement payments, including the use of offshore insurance companies to fund payments under a nonqualified structured settlement. 
• The treatment under IRC section 5891 of a factoring, or acceleration, of payments under a qualified structured settlement. 
• The role and treatment of a designated settlement fund under IRC section 468B that holds and distributes settlement proceeds. 

Moderator Mark Griffin, Partner, Davis and Harman LLP 

Speakers

• Matin Momen, Associate General Counsel, MetLife
• Chris Phanco, VP and Associate General Counsel, Pacific Life

10:40 AM – 11:00 AM | Morning Break

11:00 AM – 12:00 PM | 3B) 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.

Learning Objectives:  

• Identify recent IRS guidance (including GLAMs) relevant to outbound insurance transactions. 
• Understand common challenges in IRC §953(d) election process and insurance-related CFC issues, including §958(b)(4), §951B, and audit considerations under §954(i). 
• Evaluate emerging FET issues as applied to your organization.  
• Learn about OECD Pillar Two side-by-side agreement’s impact on insurance companies. 

Moderator Christopher James, Principal, Deloitte Tax LLP

Speakers

• Jacob Alter, Vice President, Metlife
• Norman Hannawa, Managing Director, PwC U.S. Tax LLP
• Jared A. Hermann, Attorney-Advisor, U.S. Department of the Treasury
• Chris Ocasal, Principal, Ernst & Young U.S. LLP

11:00 AM – 12:00 PM | 3C) 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.

Learning Objectives:  

• Changes made in OBBB that are most relevant to P&C insurance companies.
• Challenges associated with IRS processing and administrative issues that are impacting P&C insurance companies.
• An update on recent captive tax issues.
• An update on tax credit considerations.

Moderator Sarah Pisacich, Partner, KPMG LLP

Speakers

• Damon Dowell, Vice President, Taxation, MAPFRE Insurance
• Kristen Lawler, Tax Partner, Crowe LLP
• Kristan Rizzolo, Senior Counsel, Eversheds Sutherland (US) LLP

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 | 4B) 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.

Learning Objectives:

• Analyze key provisions in the recent CAMT notices that are relevant to taxpayers in the insurance industry. 
• Evaluate rules and considerations for relying on the existing CAMT proposed regulations and recent CAMT notices (or a combination thereof).
• Understand key dates in the CAMT guidance process.

Moderator Timothy Powell, Partner, Ernst & Young U.S. LLP

Speakers

• Aaron Maguire, Vice President-Head of Tax, Jackson National Life Insurance Company
• Monisha C. Santamaria, Principal, KPMG LLP
• Angela Walitt, Attorney-Advisor, U.S. Department of the Treasury
• Brett York, Principal, PwC U.S. Tax LLP

1:30 PM – 2:30 PM | 4C) 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.

Learning Objectives:

• Understand current market and regulatory trends affecting the taxation of insurance company investments in a rising rate environment. 
• Assess the impact of tax developments relevant to credit investments. 
• Analyze the tax treatment of hedging transactions 

Moderator Daniel Winnick, Principal, KPMG LLP

Speakers

• William C. Elwell, Head of Corporate Tax Law, Massachusetts Mutual Life Insurance Company
• Elena Romanova, Partner, Latham & Watkins LLP
• Nathan Tasso, Principal, Deloitte Tax LLP

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.

Learning Objectives:

• Summarize the content and implications of the OECD’s recent guidance on the Side-by-Side System; 
• Provide overview of and takeaways from other recent OECD developments, including the Simplified ETR Safe Harbour and Substance-based Tax Incentive Safe Harbour.  
• Review recent tax developments in Bermuda. 

Moderator Peter Sproul, Partner, PwC U.S. Tax LLP

Speakers

• Rebecca Burch, Deputy Assistant Secretary for International Tax Affairs, Department of the Treasury
• David Coon, Senior Manager, Ernst & Young U.S. LLP
• Jesse Eggert, Senior Managing Director, WNT, KPMG LLP
• Eric Lopata, Vice President, Corporate Counsel, Prudential Financial, Inc. 

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.

Learning Objectives:

• Understand important recent developments in the health industry and current state of the industry. 
• Understand response and planning opportunities for health insurers in the current environment.
• Learn about recent IRS technical guidance relevant to health insurance companies.

Moderator Lisandra Ortiz, Member, Miller & Chevalier Chartered

Speakers

• Kevin Knopf, Senior Technician Reviewer, IRS Office of Chief Counsel
• James Kress, Managing Director, PwC U.S. Tax LLP
• Alexander Krupnick, Attorney, IRS Office of Chief Counsel
• Emily C. Loefgren, Tax Senior Manager, Ernst & Young U.S. LLP

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.

Learning Objectives: 

• Guidance from the IRS and Treasury Department, including the status of guidance items on the IRS/Treasury Priority Guidance Plan. 
• Implementation of Trump accounts, which are a new type of starter retirement accounts. 
• Guidance on insurance dedicated ETFs under variable contracts. 
• The special RMD rules for distributions made in the form of an annuity.  
• The special rules for “hypothetical RMDs” to a surviving spouse beneficiary. 
• Roth-related issues affecting (1) in-plan Roth accounts, and (2) Roth catch-up contributions. 
• The status of the IRS prototype approval program for IRAs, model language, forms and update deadline. 
• Update to Employee Plans Compliance Resolution System (EPCRS) to cover IRA compliance issues. 
• Final regulations on reportable policy sales. 

Moderator Alison Peak, Partner, Davis & Harman LLP

Speakers

• Lauson Green, Special Counsel, IRS Office of Chief Counsel
• Kim Lunn, Assistant General Counsel, Northwestern Mutual
• Tamara Saverine, Vice President, Corporate Counsel, Voya Financial

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.

Learning Objectives: 

• Gain an understanding of special transaction structures for deals relating to Lloyd’s. 
• Learn the key differences that distinguish public transactions from private ones.
• Obtain color on the key features of Rep and Warranty Insurance and Tax Insurance and how they can facilitate transactions.

Moderator Daniel Priest, Partner, Debvoise & Plimpton LLP

Speakers

• Archan Hazra, Vice President & Corporate Counsel, Prudential Financial Inc.
• Jessica Hough, Partner, Skadden Arps Slate Meagher & Flom LLP
• Daniel Kheel, VP Tax Planning and Strategy, MetLife
• Thomas J. Neville, Partner, PwC U.S. Tax LLP

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. 

Learning Objectives: 

• Identify important developments in tax administration. 
• Explain recent Treasury and IRS guidance. 
• Describe recent litigation relevant to administrative practice.

Moderator Samuel Lapin, Member, Miller & Chevalier Chartered

Speakers

• David Fischer, Partner, Eversheds Sutherland (US) LLP
• Mary I. Slonina, Managing Director, KPMG LLP 

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.

Learning Objectives: 

• Changes to IRS Form 1099-R and how they affect the tax reporting obligations of insurers. 
• Reporting in connection with the conversion of a Trump account to an IRA or Roth IRA. 
• Reporting of certain permitted distributions and recontributions to IRAs and qualified plans. 
• Reporting for paid family leave and paid medical leave. 
• IRS enforcement activity, including name/TIN mismatches on Form 1099-R and distributions to foreign persons or addresses. 
• Impact of deregulation and burden reduction initiative. 

Moderator Bryan Keene, Partner, Davis & Harman LLP

Speakers

• Mike Byro, Senior Tax Counsel, The Guardian Life Insurance Company of America
• Lauson Green, Special Counsel, IRS Office of Chief Counsel
• Samera Kadry, AVP and Senior Counsel, Lincoln Financial Group
• Terri Milstead, Vice President, Tax, Protective Life Corporation

5:00 PM – 6:30 PM | Reception
Sponsored by Crowe LLP