Using Tax Insurance To Mitigate Transaction Risk and More – Sponsored by Jeffrey Gregory
TheGAAP.net Presents: Using Tax Insurance To Mitigate Transaction Risk and More Sponsored by Jeffrey Gregory Of Desjardins Financial Security Investments Inc
An interactive online zoom training on October 10, 2023 – 7:00 to 9:00 PM
The IRS, the CRA and other tax authorities often challenge specific tax treatments taken by buyers and sellers in mergers and acquisitions (M&A) and other types of transactions. Since the tax implications of these transactions are often considerable, it can be difficult to identify the resulting risks — and the parties may have differing opinions on the issue. Also, owing in part to the time constraints often involved in transactions, advance tax rulings may not be available or practical.
Tax insurance allows the taxpayer to transfer many of their risks to an insurer (or a pool of insurers), allocating them away from the transaction itself and obviating the need for special indemnities or purchase price reductions.
This Talk Will Cover
- How tax insurance works
- What it can cover and how the underwriters think about tax risk
- Why it’s important to work with an expert tax insurance broker and how to procure the insurance
- What it will cost and who are the parties involved
- The underwriting process
- How the claims process may work
About the Speaker
Tax Insurance Leader at Marsh USA, LLC
Mark is an expert in the field of transactional risk insurance for tax risk. Specifically, he focuses on creating bespoke tax insurance solutions for clients on a wide range of U.S. federal, Canadian federal, state/provincial, local, and foreign income tax matters. This includes tax insurance solutions in connection with M&A transactions and internal corporate restructurings, tax risk mitigation of on-balance sheet tax exposures, and the financing of renewable energy and carbon sequestration projects.
Mark has been in the tax community serving as an insurance broker, tax advisor, banker and sales executive for over thirty years. Prior to joining Marsh in early 2017, Mark spent five years running business development for the financial services practice at Deloitte Tax. Before that, he was a partner in a boutique investment advisory firm focused on structured finance with an emphasis on tax and accounting efficient transactions. Mark also spent over eight years at large financial institutions including Bank of America Merrill Lynch and National Australia Bank. In banking, Mark was the lead tax and accounting expert on fixed income trading desks and investment banking groups.
Prior to banking, Mark spent six years at EY where he practiced international tax (inbound and outbound), capital markets and financial product taxation, and corporation income tax.
BS, Accounting, magna cum laude, State University of New York at Albany
MBA, Finance, New York University Stern School of Business
Certified Public Accountant in the State of New York
Licensed property and casualty broker resident in the State of New York
FINRA Series 7 & and 63 securities licenses (inactive)
Norton Rose Fulbright Canada, LLP
Barry regularly advises insurers and brokers with respect to Canadian tax insurance policies. His practice also includes tax structuring and advice in the context of public and private M&A, debt restructurings, corporate reorganizations, private equity fund formation, and international tax planning.
LL.B., University of Ottawa, 1998
B.Comm., McGill University, 1994
Paul Calleri, Founder of TheGAAP.net and the CPA Toronto Accounting Group