Posted Apr 19

Corporate Counsel - Brighthouse Financial

New York, NY Full Time

Role Value Proposition:

The Product Tax Senior Counsel will be responsible for advising the enterprise with respect to the impact of tax law as it relates to insurance products. The role requires this position to research, review, analyze and apply tax law to relevant enterprise products and operations. The position is also responsible for coordinating and liaising with the tax reporting and compliance teams and front office staff. The position will involve review of tax issues related to new and actively marketed product and assist with MEC issues as well as Internal Revenue Code (IRC) Sections 101, 7702, 7702A, and 79 compliance. Products covered by this team include variable life, universal life, term life, whole life, and individual disability income products. This position will report to the Head of Employee Benefits and Products Tax.

Key Responsibilities:

Research and provide tax planning support for Brighthouse Financial’s insurance products, including variable life, universal life, term life, whole life, and individual disability products

Research and provide tax planning support for Brighthouse Financial’s annuity products, including variable, fixed, and indexed annuities

Provide tax guidance around the design of new life products (e.g., life insurance, annuities, long-term care) regarding qualification with the IRC requirements

Provide tax guidance regarding both the interpretation of IRC requirements and the procedures in place (administrative or otherwise) for monitoring compliance

Provide advice on 1035 exchanges, as well as advice on investor control and the diversification requirements of Section 817

Life insurance: advice on compliance with sections 79, 101, 7702, 7702A

Advice on the design and administration of qualified and non-qualified annuity products under IRC Sections 72, 408 and 408A

Advice on correcting excess contributions, contract reinstatements and other annuity administration issues

Qualified long-term care (riders to life policies): Section 7702B

Provide tax guidance regarding both the interpretation of IRC requirements and the procedures in place (administrative or otherwise) for the:

Identification of taxable payments to policyholders and beneficiaries

Determination of amounts includible in income for non-qualified life insurance and annuity contracts under Section 72 (e.g., cost basis determination)

Administration of required minimum distributions

Issuance of proper information returns (e.g., Forms 1099, Form 5498, 704 and state notice and consent rules)

Perform tax review of all marketing material for Brighthouse products (both life and annuity) whether branded or white label. Review for tax compliance and consistency with administrative practices. Advance market conversations with wholesalers as/when needed

Serve as a liaison to various functional areas to provide tax advice and work with the functional areas to mitigate product / policyholder tax compliance risk, including:

Actuarial (e.g., new product development: section 7702 qualification for life insurance, section 72 qualification for non-qualified annuities); MEC testing, CVAT; GPT and determining when there has been a material change and the consequences.

New business issuance (e.g., section 1035 compliance, riders, indemnification agreements between carriers)

IT (e.g., administrative system compliance, illustration systems)

Policy holder services (e.g., day to day processing of transactions to insure procedures are following and qualification requirements are met)

Payments and distribution (e.g., proper identification of payments and determination of amounts includible in income)

Tax reporting (e.g., issuance of proper information returns to owners residing in both US and non-US jurisdictions)

Support review of issues related to potential product tax noncompliance, policyholder remediation, determinations of potential liability, and remediation with the IRS as and when necessary

Support training and awareness to resources in functional areas, e.g., ad-hoc training, internal webinars, lunch-and-learns, etc.

Maintain industry awareness, assess/monitor/ track impact of new legislation and regulatory changes on company’s product tax compliance, e.g., R&D, attend industry meetings

Essential Business Experience and Technical Skills:

JD from an accredited US law school

Member in good standing of the NY Bar

Minimum 4-7 years of product tax experience in the life insurance industry or in a major law firm working with life insurance company clients

Broad experience on federal and state tax issues with significant focus on life insurance tax matters

Experience with insurance product tax IRS letter rulings, waivers, and closing agreement processes

Technical experience in insurance product taxation

Excellent writing and oral communication skills in order to engage with management effectively

Ability to assist with the resolution of technical questions and uncertainties in a manner that meets Brighthouse Financial business goals and maintains a high compliance culture

Ability to listen and appreciate stakeholder concerns and understand business issues that are affected by tax technical matters

Exhibits initiative and the ability to manage multiple complex tasks towards completion

Candidate should be flexible and motivated, a self-starter who can succeed in a fast-paced environment

In order to post for this position, you need the proper work authorization to work in the country where the position is located and not require relocation assistance.

LLM in Taxation or corresponding experience in insurance product taxation

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