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.
Attorney designs credit insurance program offered through retailers captive.
Attorney advises mutual insurer in restructuring.


Documents by this lawyer on

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Tax Court Holds that Residual Value Insurance Qualifies as Insurance for Tax Purposes
Dennis L. Allen,Thomas A. Gick,Michael R. Miles,Mary E. Monahan,William R. Pauls, September 24, 2015
On September 21, the United States Tax Court held in favor of the taxpayer in R.V.I. Guaranty Co., Ltd. and Subsidiaries v. Commissioner, 145 T.C. No. 9 (2015). The court concluded that the residual value insurance policies issued by RVI1 qualify as insurance policies for U.S. federal income tax...

IRS Extends FATCA Transition Rules
Dennis L. Allen,Robert S. Chase,Thomas A. Gick,Michael R. Miles,Mary E. Monahan, September 23, 2015
On September 18, 2015, the Internal Revenue Service (IRS) issued Notice 2015-66, in which Treasury and the IRS announced that they intend to extend certain transition rules and modify certain other reporting rules under the Foreign Account Tax Compliance Act (FATCA).

First Investor Control Case Since 1984 Is Released
Dennis L. Allen,Thomas A. Gick,Jeffrey H. Mace,Michael R. Miles,William R. Pauls, July 7, 2015
On June 30, the Tax Court released Webber v. Commissioner, 144 T.C. No.17, in which the court upheld and applied the principles set forth in the Internal Revenue Service’s (IRS) “investor control” rulings, concluding that for federal tax purposes, the taxpayer in question was the...

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Office Information

Dennis L. Allen

700 Sixth Street NW, Suite 700
WashingtonDC 20001-3980


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