Jeff Mace has more than 25 years of experience in tax, regulatory and transactional matters involving insurance and reinsurance matters. He has assisted clients in the U.S., U.K. and Bermuda with corporate acquisitions, formations, restructurings, redomiciles, M&A transactions, and capital and debt offerings as well as with regulatory enforcement actions and tax planning, structuring, and U.S. income and excise tax audits.
Jeff has acted as outside counsel to Lloyd's of London for 25 years. He has also represented a number of Lloyd's managing and member agents, as well as corporate members within Lloyd's market.
Jeff has had the opportunity to represent Lloyd's of London on a wide range of projects that impact the ability of Lloyd's members to trade in the United States. These projects have covered a wide range of disciplines. What they all have in common is a deep and intimate understanding of the Lloyd's market and its rich and long history. As outside counsel, Jeff has advised Lloyd's on matters involving U.S. income and excise taxes, U.S. state regulatory developments, U.S. federal and state legislative matters, U.S. trust fund requirements and U.S. litigation matters. Jeff has also represented Lloyd's before the Internal Revenue Service, U.S. Treasury Department, U.S. State Insurance Commissioners, U.S. Securities and Exchange Commission, State Attorney's General, New York Insurance Department (Department of Financial Services) and many other state and federal agencies. Specific matters for which Jeff has advised include:
ˇ U.S. legislation with respect to the taxation of Lloyd's income and Lloyd's members.
ˇ U.S. Treasury department study and report on the taxation of Lloyd's income and Lloyd's members.
ˇ The negotiation and implementation of the 1990 Lloyd's closing agreements covering U.S. federal income tax and federal excise tax (FET) between the U.S. Treasury, the IRS and Lloyd's of London and Lloyd's individual members.
ˇ The negotiation and implementation of the 1995 Lloyd's closing agreements covering U.S. federal income tax and FET between the U.S. Treasury, the IRS and Lloyd's of London and Lloyd's corporate members.
ˇ The negotiation and implementation of nationwide legislative changes necessary to permit Lloyd's corporate underwriters to write surplus lines and reinsurance business.
ˇ All U.S. aspects of Lloyd's plan of reconstruction and renewal (R&R), including the establishment of Equitas and the subsequent reinsurance of all Lloyd's pre-1993 business into Equitas. In this regard, Jeff advised Lloyd's on taxation issues, regulatory issues and trust fund issues, Names' litigation issues and represented Lloyd's before numerous U.S. governmental agencies.
ˇ The negotiation and implementation of the current (2005) Lloyd's closing agreements covering U.S. federal income tax and FET between the U.S. Treasury, the IRS and Lloyd's of London and Lloyd's members.
ˇ The reinsurance of all pre-1993 liabilities by Equitas to Warren Buffet's National Indemnity Insurance Company (NICO) and the subsequent UK Part VII transfer of all such liabilities.
ˇ The filing of an amicus brief in the Global Re v Equitas litigation alleging anti-trust violations against Equitas in the handling of claims.
Jeff has also advised a number of U.S. and Bermuda-based insurance and reinsurance companies on their entrance into and participation in the Lloyd's market, including those that have purchased an existing Lloyd's vehicle and those that built new Lloyd's vehicles. Likewise, Jeff has advised a number of the historical Lloyd's platforms as they have expanded beyond the Lloyd's room to establish affiliates in Bermuda and the U.S.
Outside of Lloyd's, Jeff has advised many insurance and reinsurance companies in front of the IRS, which includes representation regarding recent enforcement efforts by the agency with respect to the cascading FET issue.
Professional and Community Involvement
ˇ Member, American Institute of Certified Public Accountants
ˇ President, Board of Directors, Scleroderma Foundation
ˇ Member, Board of Directors, Scleroderma Research Foundation
Recent Speaking Engagement
ˇ Speaker, "Tax Issues Impacting U.S. Shareholders of Lloyd's Corporate Members," Conference for Shareholders of Lloyd's Corporate Members (May 14-15, 2012)
Events
A Conference for Shareholders of Lloyd's Corporate Members
May 14-15, 2012