Jim Heffernan, a member of Sutherland's Tax Practice Group, focuses his practice on a wide variety of tax matters, including tax audit and appellate work, tax litigation, National Office of the Internal Revenue Service work (such as tax rulings, technical advice, and regulations), tax legislative matters, tax planning, tax aspects of transactional matters, estate planning and estate and trust administration matters. Jim has been extensively involved with issues relating to the taxation of insurance companies and insurance products, beginning with lobbying activities in connection with the Life Insurance Company Income Tax Act of 1959. Since that time, he has worked on many and varied insurance tax matters, such as tax audits and appeals, rulings and regulations matters in the National Office of the Internal Revenue Service, legislative matters, litigation and tax planning and advice with respect to insurance companies and insurance products. Jim was formerly an adjunct professor in the graduate tax program at the Georgetown University Law Center, has appeared as a speaker at various tax institutes and programs and is the author of a number of articles on tax topics. Professional and Community Involvement · Member, Committee on Insurance Companies, Tax Section, American Bar Association · Former Chair, Subcommittee on Separate Accounts and Variable Products, Tax Section, American Bar Association Publications · Author, "Computation of Interest on Tax Underpayments and Overpayments" (December 2009) · Author, "Interest on Federal Tax Underpayments and Overpayments" (December 1, 2004) Legal Alerts Legal Alert: IRS Issues Interim Guidance on the Federal Income Tax Treatment of Annuity and Life Insurance Contracts with a Long-Term Care Insurance Feature
August 16, 2011 Legal Alert: Ready... Aim... Fire! FY 2012 Budget Proposals (Once Again) Target Insurance Companies
February 16, 2011 Legal Alert: FY 2011 Budget Contains a Number of Tax Proposals Targeting Insurance Companies
February 2, 2010 Legal Alert: IRS Issues Initial Rulings on "Contingent" Annuities
December 7, 2009 Legal Alert: Worker, Homeownership, and Business Assistance Act of 2009 Adds Five-Year Carryback Period for 2008 or 2009 Operations Losses of Life Insurance Companies
November 6, 2009 Legal Alert: Deferred Compensation Timing Rules, Rather Than Subchapter L, Govern Insurance Company's Deduction for Retiree Medical Benefits
October 28, 2009 Legal Alert: IRS Approves "Longevity" Annuity
September 28, 2009 Legal Alert: Proposed Neal Bill Reintroduced to Limit Deductibility of Offshore Related Insurance Premiums
August 3, 2009 Legal Alert: IRS Provides Guidance on PPA Rules for Employer-Owned Life Insurance
June 2, 2009 Legal Alert: IRS Rules on Long-Term Care Coverage Provided Through an Annuity Contract
May 12, 2009 Legal Alert: IRS Rules on Secondary Market Sales of Life Insurance Contracts
May 5, 2009 Legal Alert: Treasury Money Market Guarantee Program: New Developments for Insurance-Dedicated Funds
October 8, 2008 Legal Alert: Treasury Department Money-Market Mutual Fund Guaranty Program May Present Tax Issues for Insurance-Dedicated Funds
September 24, 2008 Legal Alert: IRS and Treasury Issue 2008-2009 Business Plan
September 17, 2008 Legal Alert: IRS Applies IRC Section 72(w) to Annuity Partially Accrued While a Non-Resident Alien
August 12, 2008 Legal Alert: IRS Clarifies Grandfathering Rules for Split Dollar Life Insurance Contracts
April 2, 2008 Legal Alert: DOL Proposes Small Plan Safe Harbor for Remitting Participant Contributions to Plan
March 3, 2008 Legal Alert: IRS Rules Against Qualified Long-Term Care Insurance in 401(k) Plan
February 21, 2008 Legal Alert: IRS Issues Form to Report Employer-Owned Life Insurance
February 7, 2008 Legal Alert: IRS Issues Ruling and Proposed Guidance Regarding Protected Cell Companies
January 24, 2008 Legal Alert: IRS Implements Information Reporting for Employer-Owned Life Insurance
November 19, 2007 Legal Alert: Liberalization of Variable Insurance Product Diversification Requirements Proposed
July 31, 2007 |