Christopher W. Schoen

Christopher W. Schoen: Attorney with Eversheds Sutherland (US) LLP


Chris Schoen combines his government and private practice experience to advise clients in structuring, planning and negotiating domestic and cross-border taxable and tax-free mergers, acquisitions and spin-offs. He advises primarily on matters of significance to insurance companies, specifically cross-border reinsurance and other restructuring techniques used in the insurance sector. Chris regularly counsels clients on complex consolidated return questions and handles complex international issues, including subpart F planning for insurance companies. Chris worked as an attorney/adviser and assistant to the branch chief of the Office of Chief Counsel at the Internal Revenue Service and in private practice at another law firm, prior to joining Eversheds Sutherland (US).

Chris is an adjunct professor of tax in the University of Baltimore’s graduate tax program, where he teaches a course on the taxation of affiliated corporations.

Selected Experience

Structures formation of a new municipal bond insurance company.
Advises U.S. life insurer on the divestiture of its Latin American operations.
Represents foreign life insurer in restructurings of U.S. operations.


Legal Alerts

Legal Alert: BEAT, FATCA and Insurance-proposed regulations clarify the application of the BEAT and the treatment of insurance premiums under FATCA (December 21, 2018)
On December 13, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued two sets of proposed regulations of importance to insurance companies. One set was the ...

Legal Alert: And the BEAT goes on - proposed regulations clarify the application of the base-erosion and anti-abuse tax (December 20, 2018)
On December 13, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations under section 59A of the Internal Revenue Code of 1986, as amended, ...

Legal Alert: IRS and Treasury issue proposed regulations on discounting unpaid losses (November 15, 2018)
On November 6, 2018, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued proposed regulations that address amendments to the rules for discounting unpaid losses under ...

Legal Alert: IRS provides IRC 817(h) diversification guidance on a new form of mortgage-backed security to be issued by Fannie Mae and Freddie Mac (October 24, 2018)
On October 16, 2018, the Internal Revenue Service (IRS) released Rev. Proc. 2018-54,1 which addresses the treatment of a new mortgage-backed security under the diversification rules of IRC 817(h). ...

Legal Alert: IRS issues key audit directive for life insurers (September 13, 2018)
The Internal Revenue Service (IRS) Large Business and International (LB&I) division recently released an Industry Director’s Directive (IDD) that provides key guidance for life insurers.1 The IDD is ...

Legal Alert: No rest for the weary-final regulations continue to target inversions without major changes (July 18, 2018)
INTRODUCTIONOn July 11, 2018, Treasury and the Internal Revenue Service (IRS) published final inversion regulations (TD 9834) which are largely consistent with the temporary (T.D. 9761) and ...

Legal Alert: Special treatment for motor vehicle inventory interest under new federal tax law (January 30, 2018)
The new 2017 tax law restricts the amount of interest most corporations can deduct on their returns, but includes a significant exception for automobile dealers. Under the revised version of section ...

Legal Alert: Insurance Topics We Will Be Watching in 2018 (January 16, 2018)
On its current course, this year could be both the best and the worst of times for insurance. The US economy continues to enjoy steady growth, stock indices continue to reach new highs and tax reform ...

Legal Alert: Insurance Industry Provisions in H.R. 1, the Final Tax Bill (December 21, 2017)
On December 20, 2017, the House and Senate passed the final revised version of H.R. 1 (the Final Bill), which was the result of a conference agreement between the House and the Senate in connection ...

Legal Alert: Reconciling the Differences, the Senate Tax Cuts and Jobs Act (November 16, 2017)
On November 9, 2017, the Senate Finance Committee released a Description of the Chairman’s Mark of the “Tax Cuts and Jobs Act” and on November 14, 2017, the Senate Finance Committee released a ...


What Is FATCA, and How Do Captives Handle It? (January 18, 2017)

Section 831(b) Captives as “Transactions of Interest” (January 2017)
Captive Insurance Company Reports
In their article for Captive Insurance Company Reports, Eversheds Sutherland (US) attorneys P. Bruce Wright, M. Kristan Rizzolo, Christopher Schoen and Saren Goldner discuss the Internal Revenue ...

Final and Temporary Section 385 Regulations (December 2016)
Captive Insurance Company Reports
On October 13, 2016, the Department of Treasury and the Internal Revenue Service issued temporary and final regulations (the “Final Regulations”) under IRC Section 385. The regulations address ...

Ceding Commission Held Amortizable in Reinsurance Transaction (December 2016)
Captive Insurance Company Reports
On November 14, 2016, the Internal Revenue Service (IRS) release Chief Counsel Advice (CCA) 201642032 in which the Internal Revenue Service concluded that a reinsurance transaction whereby the ...

Disclosure of 831(b) Transactions of Interest Required by IRS in Notice 2016-66 (November 3, 2016)

New Proposed Section 385 Regulations (August 1, 2016)
Captive Insurance Company Reports
In their article for Captive Insurance Company Reports, Sutherland attorneys P. Bruce Wright, Christopher Schoen and Saren Goldner review drastic changes in the corporate tax landscape for captives ...

Issues For ‘Lonely’ Life Companies Under New Debt-Equity Regulations (May 4, 2016)
Recently proposed Treasury regulations under IRC 385 would, in certain instances, treat related party debt instruments as stock for U.S. federal tax purposes. Although the proposed regulations ...

Sweeping Changes Proposed in New Debt-Equity Regulations (April 18, 2016)
Tax Notes
The Treasury Department and the IRS released proposed regulations on April 4 that aim to dramatically change the landscape for an age-old question: Does an instrument issued by a corporation to a ...

Inside the New Hedges and Mixed-Straddles Tax Guidance (August 18, 2014)
In their article for Law360, “Inside the New Hedges and Mixed-Straddles Tax Guidance,” Sutherland tax attorneys William Pauls and Christopher Schoen describe the IRS’s newly issued guidance ...

To The Direct Acquirer Belong The Tax Attributes (May 27, 2014)
The U.S. Department of Treasury and the IRS recently published proposed regulations stating the corporation that directly acquires the assets transferred in the reorganization inherits the tax ...


Eversheds Sutherland Global Tax Brief (June 2017)
The Eversheds Sutherland Global Tax Brief is a collection of tax developments from our attorneys across the globe. We hope you enjoy this issue of the Brief and look forward to sharing more updates ...

Areas of Practice (4)

  • Tax
  • Mergers & Acquisitions
  • Insurance
  • Insurance Taxation

Education & Credentials

Contact Information:
202.383.0934  Phone
University Attended:
Colgate University, B.A.; Wesleyan University, M.A.L.S., Literature
Law School Attended:
Hofstra University School of Law, J.D., Award for Excellence in Taxation, Award for Excellence in Commercial Law; New York University School of Law, LL.M., Taxation
Year of First Admission:
U.S. Tax Court; 2002, Connecticut; 1993, New York; 2001, District of Columbia

Peer Reviews

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*Peer Reviews provided before April 15, 2008 are not displayed.

Documents (4)

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Washington, District of Columbia

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