Susan E. Seabrook

SS
Attorney Awards

Biography

Susan Seabrook provides innovative solutions and strategies to a wide variety of complex tax issues faced by insurance companies, reinsurers, financial institutions and other large multinational corporations. With more than 25 years of experience, she advises on highly technical Internal Revenue Service (IRS) procedural, controversy and tax litigation matters, representing clients in all phases of examination, audit, discovery and administrative appeals.

With clients that span a variety of industries-including healthcare, finance, energy, life sciences and leasing-Susan regularly counsels on large-scale mergers and acquisitions, insurance and reinsurance transactions (life and non-life), Subchapter L issues, captives, general corporate transactional tax planning, structuring and restructuring, and tax risk assessments.

Prior to entering private practice, Susan worked for a Big Four accounting firm and the IRS Office of Chief Counsel where, for nearly 10 years, she served as a senior trial attorney and attorney advisor in the insurance branch of the Financial Institutions and Products division. As a senior trial attorney, she tried many cases and served as counsel to an IRS Exam team in a joint audit with the Japanese National Tax Administration.

A widely respected thought leader, Susan is a frequent speaker and panelist on IRS practice, controversy and tax litigation matters, and appears regularly before industry groups and at insurance tax conferences.

Awards and Rankings

Recognized by The Legal 500 United States in the area of tax controversy (2009-2011, 2014, 2018)

Recipient, IRS Special Act Award (1994, 1995, 1996)

Recipient, IRS Performance Award (1997, 1999)

Publications

Legal Alerts

Legal Alert: We are not in Kansas anymore - OECD proposes way forward for digital tax solution (February 1, 2019)
The Organisation for Economic Co-operation and Development (OECD) has issued a policy note document (Note) addressing the tax challenges of the digitalization of the economy under its action plan ...

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: Allocation, apportionment and attribution, oh my - Proposed foreign tax credit regulations provide critical guidance (December 3, 2018)
On November 28, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations concerning foreign tax credit determinations and related issues ...

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: LB&I adds new campaigns on virtual currency and transition tax (July 10, 2018)
On July 2, 2018, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced five new compliance campaigns, including campaigns relating to virtual currency ...

Legal Alert: IRS announces campaign to review corporate transaction costs (March 19, 2018)
New Campaigns AnnouncedOn March 13, 2018, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced five new compliance campaigns. The five ...

Legal Alert: IRS announces its “repair” of tangible property examinations (March 19, 2018)
New Campaigns AnnouncedOn March 13, 2018, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced five new compliance campaigns. The new ...

Articles

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 ...

Tax Planning in the Age of Tax Reform: Part 3 (March 16, 2018)
Law360
The Tax Cuts and Jobs Act (TCJA) presents both challenges and opportunities. Companies face immediate hurdles implementing the law without administrative guidance. But the combination of expiring ...

Tax Planning in the Age of Tax Reform: Part 2 (March 15, 2018)
Law360
The Tax Cuts and Jobs Act (TCJA) presents both challenges and opportunities. Companies face immediate hurdles implementing the law without administrative guidance. But the combination of expiring ...

Tax Planning in the Age of Tax Reform: Part 1 (March 14, 2018)
Law360
The Tax Cuts and Jobs Act (TCJA) presents both challenges and opportunities. Companies face immediate hurdles implementing the law without administrative guidance. But the combination of expiring ...

Taxing the Digital Economy - The Unilateral Approach (March 2, 2018)
Tax Journal
This has created significant concerns for taxation authorities around the world, which can see huge profits being generated by businesses at the forefront of the digital economy revolution but ...

Anti-Inversion Rule Down, But Not Out, With Texas Ruling (October 17, 2017)
Law360
A Texas federal court recently struck down the temporary anti-inversion regulation issued under Section 7874, which has been charged with preventing the planned merger between two US corporations as ...

Comments on Recent Practice Changes at IRS Appeals (May 9, 2017)
ABA Section of Taxation

Chapter 184A: Insurance Tax Issues in Mergers and Acquisitions: Identifying and Preserving Value and Avoiding Subchapter L Surprises (February 2017)
The Corporate Tax Practice Series published by Practising Law Institute

Altera: Rattling the IRS's Sense of Comfort in Its Rulemaking Process (January 25, 2016)
Bloomberg BNA Tax Management Memorandum

Insurance Tax Issues in Mergers and Acquisitions: Identifying and Preserving Value and Avoiding Subchapter L Surprises (November 2, 2015)
Bloomberg BNA Tax Management Memorandum

Newsletters

Eversheds Sutherland Global Tax Brief (December 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 ...

Presentations

The Importance of Procedure: Understanding Altera and the Significance of Transfer Pricing Litigation to Current and Future U.S. Tax Regulation (April 18, 2019)
TEI Detroit International Tax Day
Eversheds Sutherland (US) Partners Susan Seabrook and Mary Monahan present The Importance of Procedure: Understanding Altera and the Significance of Transfer Pricing Litigation to Current and Future ...

Global Controversy Update: Significant Cross Border Controversy Matters in the US and Europe and Implications for US Multinationals (April 18, 2019)
TEI Detroit International Tax Day
Eversheds Sutherland (US) Partners Susan Seabrook and Mary Monahan present Global Controversy Update: Significant Cross Border Controversy Matters in the US and Europe and Implications for US ...

2018 TEI Region II Tax Forum (June 4-5, 2018)
Eversheds Sutherland is a proud co-sponsor of the 2018 TEI Region II Tax Forum taking place June 4-5, 2018, at the Borgata Hotel in Atlantic City, New Jersey. The Tax Forum will include four plenary ...

Tax Executives Institute (TEI) 68th Midyear Conference (March 25-28, 2018)
Eversheds Sutherland is a proud Platinum Sponsor of the Tax Executives Institute (TEI) 68th Midyear Conference on March 25-28, 2018, in Washington, DC. The conference is held at the Grand Hyatt ...

Eversheds Sutherland Year-End Tax Seminar (November 10, 2017)
Eversheds Sutherland hosts and leads a Year-End Tax Seminar on November 10, 2017, in Malvern, Pennsylvania. Topics include: “The ‘Avrahami’ Case and Its Potential Impact on Non-Micro ...

Data Security and Privacy Obligations in Transactional and Compliance Settings (November 2-3, 2017)
Insurance Tax Conference (ITC)
Eversheds Sutherland (US) attorneys Susan Seabrook and Chris Schoen present on the panel, “Data Security and Privacy Obligations in Transactional and Compliance Settings,” at the Insurance Tax ...

Captive Insurance: The Good, the Bad and the Ugly (June 15, 2017)
New York University 9th Annual Tax Controversy Forum

Tax Controversy Update (June 2, 2017)
Federal Bar Association’s 29th Annual Insurance Tax Seminar

Surviving an IRS Audit in a New Landscape (May 24, 2017)
Financial Research Associates’ 8th Annual Private Investment Fund Tax Master Class

Litigating Captive Insurance Cases - Industry Update on the IRS’ New Campaigns (May 13, 2017)
ABA Section of Taxation’s 2017 Spring Meeting

News

In the News

FBARs: A Changing Landscape (April 4, 2018)
Law360
Eversheds Sutherland’s videocast regarding civil and criminal enforcement of Foreign Bank and Financial Accounts (FBAR) is featured in Law360. In this video, Eversheds Sutherland Partners James ...

Insurance Advocates Fear Revival of Flawed Proration Rules (October 31, 2017)
Tax Notes
Eversheds Sutherland Partner Susan Seabrook is quoted in this Tax Notes article discussing the impacts legislators could have on insurance companies if they revive certain provisions from the 2014 ...

Insurance Advocates Hope Camp Proposals Stay Dead (September 15, 2017)
Tax Notes
Eversheds Sutherland Partner Susan Seabrook is quoted in this Tax Notes article regarding the Tax Reform Act of 2014 made by former House Ways and Means Committee Chair Dave Camp. More specifically, ...

Avrahami Decision Offers Microcaptives Details, No Bright Line (August 23, 2017)
Tax Notes
Eversheds Sutherland Partners Saren Goldner and Susan Seabrook are quoted in this Tax Notes article regarding the decision in Avrahami v. Comm’r, a microcaptive insurance case in which Judge Mark V. ...

Eversheds Sutherland Adds Tax Partner (August 13, 2017)
CityBizList - Washington DC
Susan Seabrook is featured in this Washington CityBizList article for joining Eversheds Sutherland's Tax Practice Group as a partner in Washington DC. With more than 25 years of experience, she ...

Susan Seabrook Bolsters Tax Controversy and Insurance Taxation Practices in Washington DC (August 10, 2017)
Patch - Washington DC
Susan Seabrook is featured in this Washington Patch article for joining Eversheds Sutherland's Tax Practice Group as a partner in the Washington DC office.

People on the Move - Susan Seabrook (August 10, 2017)
Washington Business Journal
Susan Seabrook is mentioned in this Washington Business Journal article for joining Eversheds Sutherland’s Tax Practice Group as a partner in the Washington DC office.

Advocates Aim to Preserve Like-Kind Exchange in Tax Reform (May 5, 2017)
Tax Notes

Updates to Fast-Track Settlement Program Draw Concerns (March 22, 2017)
Tax Notes

Reinsurance Transactions Under a Destination-Based Cash Flow Tax (February 28, 2017)
Tax Notes

Press Releases

18 Eversheds Sutherland Practice Areas, 68 Attorneys Named Among Nation’s Best in 2018 Legal 500 United States (May 30, 2018)
Eversheds Sutherland (US) LLP is pleased to announce that 18 practice areas and 68 attorneys have been recognized in the 2018 edition of The Legal 500 United States, a comprehensive survey of legal ...

Eversheds Sutherland Bolsters Tax Controversy and Insurance Taxation Practices with Addition of US Partner Susan Seabrook (August 10, 2017)
WASHINGTON-Eversheds Sutherland is pleased to announce that Susan E. Seabrook has joined the Tax Practice Group as a partner in the Washington DC office. Prior to joining Eversheds Sutherland, Ms. ...

Multimedia

Videocast: Taxation of the digital economy (September 13, 2018)
Significant profits are being generated by the “digital economy” while revenue authorities question the ability of traditional physical presence-based tax rules to properly capture earnings. In this ...

Videocast: Tools of engagement-best practices to maximize certainty and minimize controversy (April 9, 2018)
The tax reform bill passed at the end of 2017, but Congress continues to propose and make changes to the Internal Revenue Code. Many provisions provided welcome relief; others created uncertainty. ...

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 ...

Videocast: FBARs - a changing landscape (March 29, 2018)
Civil and criminal enforcement of Foreign Bank and Financial Accounts (FBAR) violations are on the rise. This Bottom Line videocast discusses the changes to the rules impacting FBAR filing ...

Videocast: Tax Planning in the Age of Tax Reform: Procedural Options Under Review - Best Practices for Avoiding or Minimizing Controversy (March 6, 2018)
In light of the major changes to the Internal Revenue Code (the Code) resulting from the recent enactment of the Tax Cuts and Jobs Act (TCJA), now more than ever, companies have the opportunity to ...

Areas of Practice (7)

  • Tax
  • Tax Controversy & Litigation
  • Insurance Taxation
  • Reinsurance
  • Insurance Finance
  • Cybersecurity & Privacy
  • Digital Economy

Education & Credentials

Contact Information:
202.383.0919  Phone
202-4527989  Fax
www.eversheds-sutherland.com
University Attended:
University of Colorado at Boulder, B.A.
Law School Attended:
University of Denver College of Law, LL.M.; Gonzaga University, J.D.
Year of First Admission:
2001
Admission:
U.S. District Court for the District of Columbia; U.S. District Court for the Puerto Rico; U.S. Court of Federal Claims; U.S. Tax Court; U.S. District Court for the Arizona; Arizona; District of Columbia; U.S. Court of Appeals for the First Circuit; U.S. Supreme Court
Memberships:

Professional Activities

Member, American Bar Association, Section of Taxation
Member, Federal Bar Association, Section of Taxation
Member, The Sedona Conference, Working Groups 6 and 11
Member, National Association of Women Lawyers
Vice President and Secretary, Insurance Tax Conference
Master, Edgar Murdock (Tax Court), American Inns of Court

ISLN:
903884547

Peer Reviews

5.0/5.0 (1 review)
Peer Reviewed
  • Legal Knowledge

    5.0/5.0
  • Analytical Capability

    5.0/5.0
  • Judgment

    5.0/5.0
  • Communication

    5.0/5.0
  • Legal Experience

    5.0/5.0

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

Washington, District of Columbia

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