M. Kristan Rizzolo

M. Kristan Rizzolo: Attorney with Eversheds Sutherland (US) LLP

Biography

With more than 25 years of advising insurance and reinsurance clients on federal tax issues, Kristan Rizzolo helps clients maximize tax efficiency in their business operations. She counsels clients in tax planning, including the tax implications of creating or operating captive insurance and reinsurance companies and various tax considerations associated with qualified and non-qualified structured settlement programs. Kristan regularly advises global and domestic insurance and reinsurance clients on multinational mergers, acquisitions, divestitures and offshore agreements, including the application of tax treaties, FATCA and other issues arising out of cross border transactions.

Kristan has extensive experience with the tax controversy and litigation process at the federal level and represents clients before the Internal Revenue Service, the U.S. Tax Court, the U.S. Court of Federal Claims and the U.S. Supreme Court. She advises clients on audits and appeals in addition to representing them on regulatory matters.

Before joining Eversheds Sutherland (US), Kristan was a partner at Dewey & LeBoeuf LLP. Earlier in her career, she was a law clerk for the Honorable Charles E. Clapp, II of the U.S. Tax Court.

Clerkships

Honorable Charles E. Clapp, II of the U.S. Tax Court

Experience

“When I work with a client, I try to really get to know their business and what their issues are. Clients come back again and again because I understand their business and how it operates.”

Experience

Successfully represented residual value insurer in U.S. Tax Court.
Counseled insurance companies on tax issues related to acquisitions and divestitures.
Advised numerous corporate groups on an array of federal tax policy matters regarding captive insurers.
Represented client in IRS audit and appeal.
Advises insurance group on structured settlement programs.
Advised numerous clients on the implications of the 2017 tax legislation for the insurance industry.

News

In the News

Eversheds Sutherland Says 30 Percent of Equity Partners to Be Women by 2021 (June 7, 2018)
Daily Report
Eversheds Sutherland Co-CEO Mark Wasserman and US Partner Kristan Rizzolo are featured in this Daily Report article discussing a new initiative to transform the gender balance of the US partnership, ...

IRS Unveils Issue-Focused Corporate Compliance Campaigns (February 2, 2017)
Tax Notes
Eversheds Sutherland (US) Partner Kristan Rizzolo is quoted in this Tax Notes article regarding 13 corporate compliance initiatives undertaken by the Internal Revenue Service. One campaign includes ...

IRS Notice Requires Micro-Captive Transaction Reporting (November 3, 2016)
Tax Analysts
Sutherland Partner M. Kristan Rizzolo is quoted in this Tax Analysts article regarding micro-captive transactions and how the Internal Revenue Service (IRS) issued Notice 2016-66 as an initial step ...

What Is Insurance? An Old Question Made More Pressing Recently (June 6, 2016)
Tax Notes Today
Sutherland Partner M. Kristan Rizzolo is quoted in this Tax Notes Today article regarding a question that the Internal Revenue Service has been dealing with for years: what constitutes insurance? ...

Relevance of U.S. Captive Insurance Guidance Questioned (June 1, 2015)
Worldwide Tax Daily and Tax Notes
Partner M. Kristan Rizzolo is quoted in articles for Worldwide Tax Daily and Tax Notes regarding Rev. Rul. 2005-40, 2005-27 IRB 4 and how the Internal Revenue Service must clarify whether the entity ...

‘Validus’ Decision Favors Foreign Reinsurer, Eliminates IRS ‘Cascading’ Excise Tax Theory (May 26, 2015)
Bloomberg Law - Daily Report for Executives
Partner M. Kristan Rizzolo is quoted in this Bloomberg Law article regarding the U.S. Court of Appeals for the District of Columbia Circuit decision in Validus Reinsurance, Ltd. v. United States, ...

Press Releases

Eversheds Sutherland Partner M. Kristan Rizzolo Elected to American College of Tax Counsel (February 15, 2019)
Eversheds Sutherland is pleased to announce that Partner M. Kristan Rizzolo was elected to the American College of Tax Counsel (ACTC). The ACTC is composed of lawyers who have more than 15 years of ...

Eversheds Sutherland Women’s Initiative Expands with Post-Combination Perspective (May 21, 2018)
Eversheds Sutherland (US) LLP is excited to announce the expansion of its women’s initiative following its international combination last year. Moving forward with new centralized leadership and a ...

Multimedia

Videocast: Tax Reform and the Insurance Industry (April 5, 2018)
The tax reform bill passed at the end of 2017 includes a number of changes specific to the insurance industry. These provisions, in conjunction with other changes brought about by the new law, can ...

Publications

“When dealing with insurers on tax issues, you have to know the ins and outs of the insurance industry, including insurance products and how contracts in the sector are put together.”

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: 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: Tax Cuts and Jobs Bill Update, November 14: Major Insurance Industry Changes (November 14, 2017)
As noted in a previous Eversheds Sutherland Legal Alert, on November 2, the House Ways and Means Committee released the “Tax Cuts and Jobs Act” (H.R. 1) (the House Bill). An amended version of the ...

Legal Alert: Tax Cuts and Jobs Bill: Major Insurance Industry Changes (November 8, 2017)
On November 2, 2017, the House Ways and Means Committee released the “Tax Cuts and Jobs Act” (H.R. 1) (the Bill). The Bill already has been amended and likely will undergo further revision before it ...

Legal Alert: Tax Court Decides First Micro Captive Case (August 24, 2017)
On August 21, 2017, the Tax Court issued its opinion in two companion cases Benyamin Avrahami and Orna Avrahami v. Commissioner, and Feedback Insurance Company, Ltd. v. Commissioner, 149 T.C. No. 7, ...

Articles

Are You An Inadvertent US Shareholder In A Foreign Corp? (October 19, 2018)
Law360
Prior to the Tax Cuts and Jobs Act, US companies typically structured their minority investments in non-US corporations to limit the risk that the controlled foreign corporation, or CFC, rules would ...

Preparing For New Life Settlement Transactions Reporting (September 18, 2018)
Law360
Those involved in life settlement transactions will have to pay close attention to new information reporting requirements included in the Tax Cuts and Jobs Act President Donald Trump signed into law ...

Back To The Future: The Insurance Industry And Tax Reform (May 16, 2018)
Law360
Over the years, Congress has repeatedly overhauled the insurance-specific provisions of the Internal Revenue Code, which are found in Subchapter L. For example, under the Revenue Act of 1918, both ...

A Tax Court Opinion in Avrahami-Finally (October 2017)
Captive Insurance Company Reports
On August 21, 2017, the US Tax Court issued its long-awaited opinion in the companion cases of Avrahami v. Commissioner and Feedback Ins. Co., Ltd. v. Commissioner, 149 T.C. No. 7 (2017), holding ...

IRS Addresses Insurance Characterization (August 2017)
Captive Insurance Company Reports
A recent Chief Counsel Advice (CCA) released by the IRS employee benefits division of the Office of Chief Counsel is the latest statement by the IRS on the issue of “what is insurance.” In CCA ...

What Is a Reciprocal Insurance Company, and How Is It Taxed? (March 1, 2017)
Captive.com

Direct Procurement Taxes: A Primer for Captives (February 22, 2017)
Captive.com

Group Captives, Cell Captives, and Risk Pooling Arrangements Guide (February 1, 2017)
Captive.com

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

Taxation of Single-Parent Captives: A Basic Guide (January 12, 2017)
Captive.com

Newsletters

Eversheds Sutherland Global Tax Brief (October 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 ...

Eversheds Sutherland Global Tax Brief (July 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 ...

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

Eversheds Sutherland Global Tax Digest (March 2017)
Introducing the Eversheds Sutherland Global Tax Digest-a collection of tax developments from our attorneys across the globe. With the combination of Eversheds and Sutherland came expanded ...

Presentations

“I am a generalist and a specialist. My practice covers numerous aspects of the tax code, but it focuses on the insurance industry.”

Presentations

BEAT and GILTI Issues for Insurance Companies (January 18, 2019)
American Bar Association (ABA)
Eversheds Sutherland (US) Partner Kristan Rizzolo presents BEAT and GILTI Issues for Insurance Companies at the ABA Tax Section Midyear Meeting on January 18, 2019, in New Orleans, Louisiana.

Property and Casualty Insurers of America Northeast General Counsel Seminar (September 18, 2017)
Eversheds Sutherland is a proud sponsor of the Property and Casualty Insurers of America Northeast General Counsel Seminar. Eversheds Sutherland (US) Partner Kristan Rizzolo presents Federal Agency ...

Current Developments in Captive Insurance Companies (September 14-16, 2017)
American Bar Association (ABA)
Eversheds Sutherland (US) Partner Kristan Rizzolo presents on the panel, “Current Developments in Captive Insurance Companies,” at the American Bar Association 2017 Joint Fall CLE Meeting on ...

NYU 9th Annual Tax Controversy Forum (June 15 - 16, 2017)
NYU 9th Annual Tax Controversy Forum
Eversheds Sutherland is a proud sponsor of the NYU 9th Annual Tax Controversy Forum, taking place June 15-16, 2017, in New York, New York. (US) Partner Tom Cullinan participates on the panel “LB&I ...

The Latest on Captive Insurance (May 12, 2017)
ABA Section of Taxation May Meeting
Eversheds Sutherland (US) Partner Kriss Rizzolo presents on the panel, “The Latest on Captive Insurance” at the ABA Section of Taxation May Meeting on May 12, 2017, in Washington, DC.

What Is Insurance? (May 6, 2016)
ABA May Meeting
Sutherland Partner Kristan Rizzolo moderates the “What Is Insurance?” panel at the ABA May Meeting on May 6, 2016, in Washington, DC.

Reinsurance Update (September 18, 2015)
ABA Joint Fall CLE Meeting
Sutherland Partner Kriss Rizzolo presents a “Reinsurance Update at the ABA Joint Fall CLE Meeting in Chicago, Illinois on September 18. In this presentation, Kriss will join other ...

Litigation Update on What is Insurance (May 29, 2015)
FBA - Annual Insurance Tax Seminar
Sutherland Partner Kristan Rizzolo presents Litigation Update on What is Insurance at the FBA - Annual Insurance Tax Seminar on May 29, 2015, in Washington, DC.

Not Exactly Reassuring: Potential Impacts of Recent IRS Reinsurance Guidance (May 27, 2015)
Property Casualty Insurers Association of America Federal Tax Meeting
Sutherland Partners William R. Pauls and M. Kristan Rizzolo present Not Exactly Reassuring: Potential Impacts of Recent IRS Reinsurance Guidance at the Property Casualty Insurers Association of ...

The Time Is Now: FATCA Implementation for P&C Insurance Companies (May 28, 2014)
Property Casualty Insurers Association of America Federal Tax Meeting
Sutherland Partners William R. Pauls and M. Kristan Rizzolo present The Time Is Now: FATCA Implementation for P&C Insurance Companies at the Property Casualty Insurers Association of America ...

Areas of Practice (10)

  • Tax
  • International Tax
  • Mergers & Acquisitions
  • Insurance
  • Insurance Taxation
  • Tax Controversy & Litigation
  • Insurance M&A and Demutualizations
  • Insurance Products
  • Federal Tax
  • Captives

Education & Credentials

Contact Information:
202.383.0908  Phone
www.eversheds-sutherland.com
University Attended:
George Washington University, B.A., magna cum laude
Law School Attended:
George Washington University, J.D., with honors; Georgetown University Law Center, LL.M., with distinction
Year of First Admission:
1991
Admission:
U.S. Tax Court; U.S. Court of Appeals for the Fourth Circuit; U.S. Court of Federal Claims; U.S. Court of Appeals for the Ninth Circuit; 1993, District of Columbia; 1991, Virginia; U.S. Supreme Court
Memberships:

Professional Activities

Member, Bar Association of the District of Columbia
Member, Virginia Bar Association
Chair, American Bar Association, Section of Taxation, Insurance Companies Committee
fellow, American College of Tax Counsel

ISLN:
901258296

Peer Reviews

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

Documents (11)

Documents by this lawyer on Martindale.com

Washington, District of Columbia

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