George Hani, Maria O'Toole Jones, and Lisandra Ortiz will speak at the 49th Annual Insurance Tax Conference - Chicago on November 7, 2024. 

Jones will moderate and Hani will present "Current Trends in Federal Tax Controversies," addressing recent developments in the tax controversy area. This session will cover new IRS enforcement efforts and developments in IRS examinations, including the application of the economic substance doctrine, and new ADR procedures from the IRS Independent Office of Appeals. 

Jones will moderate and Ortiz will present "Recent Supreme Court Decisions and APA Cases." This session will cover the most recent cases of importance in the tax world, including the Supreme Court's decisions in Loper Bright, Relentless, Corner Post, and Moore. The panel will explain how these cases: change the law regarding deference to agencies; impact the statute of limitations for challenging governmental regulations; and provide insight regarding the future taxation of unrealized gains. Finally, the panel will discuss tax cases involving the Administrative Procedure Act challenges to Department of Treasury and IRS rulemaking.

Ortiz will also present, as a part of a panel, "If It's Not Insurance, What Is It?" This panel will discuss increased IRS scrutiny of insurance arrangements and provide updates on IRS challenges to taxpayer positions and address, from a financial products perspective, how insurance arrangements may be recharacterized based on the economics characteristics of an arrangement.