Introduction
We seek a tax insurance underwriter (an "Underwriter"), a specialized professional with a JD, LLM and Big Law experience, who evaluates risks associated with specific tax positions to provide insurance coverage. Tax insurance policies protect taxpayers against the loss of a tax benefit or the imposition of a tax liability by authorities like the IRS or courts.
Job Overview
The Underwriter would sit at the intersection of complex tax law and corporate finance working with a senior tax underwriter. He or she would analyze low probability, high magnitude tax risks in the context of renewable energy investments.
Key Responsibilities
Risk Analysis and Due Diligence
- Review extensive factual materials, tax memos, and other legal opinions, and perform legal research to assess the strength of a tax position.
- Evaluate the likelihood of a successful challenge by tax authorities.
- Analyze transaction structures for potential pitfalls.
Policy Execution
- Drafting: Write bespoke insurance policies that define exactly which tax risks are covered and which are excluded.
- Pricing: Determine the appropriate premium based on the complexity and soundness of the tax position.
- Negotiation: Work with brokers and clients to finalize coverage limits and retention amounts.
- Documentation: Maintain accurate and detailed records of underwriting activities to ensure compliance and support effective communication with stakeholders
Business Development
- Collaborate with others to integrate insurance into a broader insurance business.
- Stay current on legislative changes, court cases, regulatory guidance and professional commentary to be up-to-date with the latest views on tax matters from the government and private bar and to identify new areas for insurance coverage.
Qualifications & Skills
- Education: A Juris Doctor (JD) and Master of Laws (LL.M.) in taxation.
- Experience: 10+ years of experience in a Big Law tax department.
- Analytical Rigor: Ability to digest quickly hundreds of pages of documents to find, understand and evaluate tax risk.
- Commercial Awareness: Understanding how a tax law risk fits into a business deal.
- Team Player: Ability and willingness to collaborate with multiple stakeholders in a multinational company
Common Risks Underwritten
- Tax Credits: Ensuring the eligibility of renewable energy projects for investment tax credits or production tax credits.
This job description is not designed to cover or contain a comprehensive listing of activities, duties or responsibilities that are required of the employee. Other duties, responsibilities and activities may change or be assigned at any time with or without notice.
