Insurance Tax Controversy

Sidley’s Insurance Tax Controversy practice represents clients in audits, administrative appeals and in litigation of federal and state tax controversies of significant interest to the insurance industry. Our regular insurance tax clients include major life and property-casualty insurance companies and insurance industry trade associations. We also represent captive insurers, banks, utilities, national retailers, manufacturing companies and not-for-profit organizations with respect to insurance tax issues.

A particular focus of our practice is favorably resolving disputes without litigation. We believe that by resolving disputes at the earliest stage, we are able to provide our clients with favorable resolution of their tax dispute without the additional costs, distraction of internal resources and publicity that necessarily accompany any formal tax litigation. In recent years, we have resolved many issues on favorable terms before the dispute has advanced to litigation.

Although we are successful in helping clients obtain favorable administrative disposition of tax controversies in many of the cases we handle, we have also had great success in litigating tax cases for clients when satisfactory settlement at the administrative level proved to be unattainable, or when clients contacted us after exhausting all administrative options.