Dennis L. Allen

Washington,  DC  U.S.A.

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AV® Preeminent

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Practice Areas

  • Insurance
  • International Tax
  • Mergers & Acquisitions
  • Tax Controversy & Litigation
  • Federal Tax
  • Insurance Taxation
  • Insurance M&A and Demutualizations
  • Insurance Products
  • Tax
Contact InfoTelephone: 202.383.0906
Fax: 202-637-3593
University Augustana College, B.A., summa cum laude
Law SchoolUniversity of Notre Dame Law School, J.D., magna cum laude
Admitted1980, Illinois; 1981, District of Columbia; U.S. Supreme Court; U.S. Court of Federal Claims; U.S. Tax Court; U.S. Court of Appeals for the Eighth Circuit; U.S. Court of Appeals for the District of Columbia; Supreme Court Illinois; Superior Court District of Columbia; Court of Appeals District of Columbia

Professional Activities
Member, American Bar Association, Section of Taxation, Committee on Insurance Companies
Member, American Institute of Certified Public Accountants


With more than 30 years of representing clients in the insurance industry, Dennis Allen brings a creative combination of tax, insurance, product development and tax accounting experience to his counseling of major insurance and reinsurance groups, insurance intermediaries and large commercial insureds. Dennis actively works with his clients to design and develop innovative insurance and reinsurance products. He advises on the tax implications of domestic and international mergers and acquisitions, insurance company restructurings, and business acquisitions. In addition, Dennis represents clients in tax controversy matters.

Before attending law school, Dennis worked as a certified public accountant. He has taught university courses in business law, auditing and accounting.

Selected Experience

Sutherland attorney represents insurer before U.S. Tax Court.
A Sutherland attorney litigated in the U.S. Tax Court on behalf of a residual value insurance company, defending the company's status as an insurance company for tax purposes.

Attorney designs credit insurance program.
A Sutherland attorney designed and implemented a credit insurance program for a major U.S. retailer.

Attorney advises mutual insurer in restructuring.
A Sutherland attorney provided tax advice concerning the mutual insurance company's conversion and group restructuring.

Professional Activities

Member, American Bar Association, Section of Taxation, Committee on Insurance Companies

Member, American Institute of Certified Public Accountants


Documents by this lawyer on

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Required Summer Reading: Guidance Issued on the Tax Treatment of Guaranteed Minimum Benefit Hedges and Identified Mixed Straddles
Dennis L. Allen,Thomas A. Gick,Jerome B. Libin,Jeffrey H. Mace,Michael R. Miles, July 24, 2014
Treasury and the IRS offered two pieces of highly anticipated guidance on July 18 that are particularly relevant to the life insurance industry.

After All the Preparation, It’s Finally Here: FATCA Becomes Effective July 1, 2014
Dennis L. Allen,Robert S. Chase,Thomas A. Gick,Jerome B. Libin,Jeffrey H. Mace, July 9, 2014
More than four years after Congress enacted the Hiring Incentives to Restore Employment Act of 2010, Pub. L. 111-147, which added the Foreign Account Tax Compliance Act (FATCA) provisions to the Internal Revenue Code, FATCA will become effective on July 1, 2014. While the importance of this date...

Beta Testing FATCA: IRS Declares 2014 and 2015 as a Transition Period for FATCA Administration and Enforcement and Provides an Additional Six Months of Relief for Certain Preexisting Obligations
Dennis L. Allen,William R. Pauls,Linda A. Sciuto,W. Mark Smith,William J. Walderman, May 13, 2014
Pursuant to Notice 2014-33 (the Notice), the IRS announced that it will treat calendar years 2014 and 2015 as a transition period for the administration and enforcement of the due diligence, reporting, and withholding provisions of the Foreign Account Tax Compliance Act (FATCA). During this...

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Office Information

Dennis L. Allen

700 Sixth Street NW, Suite 700
WashingtonDC 20001-3980


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