Corporate Counsel: Product Tax The candidate will be responsible for providing advice with respect to the impact of tax law as it relates to the companys insurance products. Will research, review, analyze and apply tax law to relevant enterprise products and assist operations and product areas on tax questions and issues relating to new business and in-force administration. Will involve review of tax issues related to new and actively marketed product and assist with MEC issues as well as Internal Revenue Code (IRC) Sections 101, 7702, 7702A. Products covered by this team include annuities and life insurance. Research and provide tax support for Company life insurance products, including variable life, universal life, term life, whole life. Research and provide tax support for Company annuity products, including variable, fixed, and indexed annuities in the following tax markets: non-qualified annuities and qualified (IRAs, Roth IRA, and qualified plans). Provide tax guidance around the design of new life products (e.g., life insurance, annuities, Hybrid Life Insurance with long-term care coverage) regarding qualification with the IRC requirements. Provide tax guidance regarding both the interpretation of IRC requirements and the procedures in place (administrative or otherwise) for monitoring compliance. Provide advice on 1035 exchanges. Advice on the design and administration of qualified and non-qualified annuity products under IRC Sections 72, 408 and 408A. Provide guidance on the development and administration of Qualified Long-Term Care insurance (LTC) coverage (riders to life policies): Section 7702B. As needed, provide guidance on issuance of proper information returns (e.g., Forms 1099, Form 5498, 712 and state notice and consent rules). Perform tax review of all marketing material for Brighthouse products (both life and annuity) whether branded or white label. Review for tax compliance and consistency with administrative practices. Advance market conversations with the Advance Markets team and wholesalers as/when needed. Serve as a liaison to various functional areas to provide tax advice and work with the functional areas to mitigate product / policyholder tax compliance risk, including: Support review of issues related to potential product tax noncompliance, policyholder remediation, determinations of potential liability. Support training and awareness to resources in functional areas, e.g., ad-hoc training, internal webinars, lunch-and-learns, etc. Maintain industry awareness, assess/monitor/ track impact of new legislation and regulatory changes on companys product tax compliance, including attendance at industry meetings.
The candidate should have JD degree from accredited US law school. Member in good standing of a state Bar. Should have 3-6 years of product tax experience in the life insurance industry or in a major law firm working with life insurance company clients. Experience on federal and state tax issues with significant focus on life insurance tax matters. Technical experience in insurance product taxation. Excellent writing and oral communication skills in order to engage with management effectively. Ability to assist with the resolution of technical questions and uncertainties in a manner that meets company business goals and maintains a high compliance culture. Ability to listen and appreciate stakeholder concerns and understand business issues that are affected by tax technical matters. Exhibits initiative and the ability to manage multiple complex tasks towards completion. Should be flexible and motivated, a self-starter who can succeed in a fast-paced environment. LL.M. in Taxation or corresponding experience in insurance product taxation a plus.
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