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.
Attorney advises mutual insurer in restructuring.


Documents by this lawyer on

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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...

Validus Affirmed for All the Right Reasons - The FET Does Not Apply to Wholly Foreign Reinsurance Transactions
Dennis L. Allen,Thomas A. Gick,Jeffrey H. Mace,Michael R. Miles,Mary E. Monahan, June 1, 2015
On May 26, the U.S. Court of Appeals for the District of Columbia affirmed the result of the U.S. District Court for the District of Columbia in Validus Reinsurance, Ltd. v. U.S., 19 F. Supp. 3d 225 (2014), which was the first case to involve a challenge to the Internal Revenue Service’s...

IRS Releases Favorable Private Letter Ruling on “Taxable Annuity.”
Dennis L. Allen,Thomas A. Gick,Jeffrey H. Mace,Michael R. Miles,William R. Pauls, April 16, 2015
On April 10, the Internal Revenue Service (IRS) released PLR 201515001 (Oct. 10, 2014), favorably addressing a “taxable annuity” - essentially, a deferred annuity contract supported, in part, by subaccounts, each of which invested solely in a single publicly available mutual fund. Not...

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Office Information

Dennis L. Allen

700 Sixth Street NW, Suite 700
WashingtonDC 20001-3980


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