Saren Goldner focuses her practice on international tax, insurance, reinsurance and insurance tax issues, including structuring non-U.S. operations, captive insurance companies, insurance characterization and other insurance specific tax issues. She advises clients on public and private securities offerings (including securitizations and catastrophe bonds), the structuring of international insurance operations, (including the application of tax treaties, FATCA, the CFC, and PFIC rules and other tax issues arising as a result of cross border operations), the formation and operation of captives and cell companies and tax exempt issues.
Saren was tax counsel at a large international law firm before joining Eversheds Sutherland (US). In addition, she served as a judicial clerk for the Honorable Herbert L. Chabot at the United States Tax Court.
Clerkships
Honorable Herbert L. Chabot, United States Tax Court
Awards and Rankings
Recognized by Chambers USA: Guide to Leading Business Lawyers in the area of tax (2019-2020)
Experience
“I thoroughly enjoy working with the U.S. international tax rules. Most of my work involves helping non-U.S. insurance companies or investors in those non-U.S. insurance companies deal with the U.S. tax rules.”
Experience
Advised non-U.S. insurers on formation, restructurings, IPOs and other securities offerings, including sidecars and catastrophe bond issuances.
Advised investors on insurance investments.
Represented a reinsurance-linked securities fund in its formation and restructuring.
Provided U.S. tax advice on forming a member at Lloyd's of London.
Provides U.S. tax advice on catastrophe bond issuances.
Represented a Bermuda reinsurance company in its structuring and formation, the private offering of its securities, and the establishment of its business.
Represented client in IRS audit and appeal.
News
In the News
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. ...
Law360 Names Attorneys Who Moved Up the Firm Ranks in Q1 (April 28, 2017)
Law360
Saren Goldner, James Hannon and Stacey McGavin Mohr are mentioned in this Law360 article for being elected to partner, effective January 1, 2017.
Sutherland Elects New Partners and Counsel (January 18, 2017)
Atlanta Patch
Atlanta Patch mentioned 12 Sutherland attorneys for their election to partners and counsel, effective January 1, 2017.
Firm Says Proposed Reinsurance Regulations Are Too Broad, Unclear (October 1, 2015)
Insurance Tax Review
Sutherland attorneys P. Bruce Wright and Saren Goldner are featured in this Insurance Tax Review article for commenting on proposed regulations on hedge fund reinsurance arrangements.
Press Releases
24 Eversheds Sutherland Practice Areas, 63 Attorneys Named Among Nation’s Best in 2020 Chambers USA (April 23, 2020)
Eversheds Sutherland is pleased to announce that 24 practices and 63 attorneys have earned recognition in the 2020 edition of Chambers USA: America’s Leading Lawyers for Business. Chambers USA, a ...
Eversheds Sutherland 2016 Pro Bono Hours Add Up for Worthwhile Causes (July 31, 2017)
Eversheds Sutherland is pleased to announce that its attorneys spent more than 15,000 hours on 614 pro bono matters in 2016. The cases, which ranged from contract disputes to high-profile asylum ...
Sutherland Elects New Partners and Counsel (January 18, 2017)
Sutherland Asbill & Brennan LLP is pleased to announce the election of three new partners and nine new counsel, effective January 1, 2017. “Each of these attorneys provide excellent service to the ...
Sutherland Attorneys Publish Updated Insurance Regulation Answer Book with Practising Law Institute (August 31, 2016)
NEW YORK-Sutherland Asbill & Brennan LLP is pleased to announce the publication of the 2017 edition of the Insurance Regulation Answer Book, a high-level overview of the legal and regulatory ...
Presentations
Captive Insurance Tax Forum (February 25-26, 2020)
Eversheds Sutherland Partners Saren Goldner and Bruce Wright present at the Captive Insurance Tax Forum on February 25-26, 2020, in Atlanta, Georgia. Saren's presentations include:What is ...
Evolution of Captive Taxation: Recent Developments & Best Practices (December 12, 2019)
Vermont Captive Insurance Association (VCIA)
Eversheds Sutherland Partner Saren Goldner presents on the VCIA Evolution of Captive Taxation: Recent Developments & Best Practices webcast on December 12, 2019.
Captive Insurance Tax Forum (October 28-29, 2019)
Eversheds Sutherland Partners Saren Goldner and Bruce Wright present at the Captive Insurance Tax Forum on February 25, 2019, in Phoenix, Arizona. Saren's presentations include:“Potential Tax ...
How the New Proposed Passive Foreign Investment Company Regulations Affect Captives (September 26, 2019)
ABA Business Law Section’s Captive Insurance Committee
Eversheds Sutherland Partner P. Bruce Wright moderates and Partner Saren Goldner presents on a webcast, How the New Proposed Passive Foreign Investment Company Regulations Affect Captives, hosted ...
Direct Procurement, Related State Tax Issues and Federal Excise Taxes (September 17, 2019)
Minnesota Chapter of the Risk and Insurance Management Society (RIMS)
Eversheds Sutherland Partners Saren Goldner and Bruce Wright present Direct Procurement, Related State Tax Issues and Federal Excise Taxes at the Minnesota Chapter of the Risk and Insurance ...
Captive Insurance Tax Forum (February 25-26, 2019)
Eversheds Sutherland Partners Saren Goldner and Bruce Wright present at the Captive Insurance Tax Forum on February 25-26, 2019, in Miami, Florida. Saren's presentations include:“Potential Tax ...
Base erosion and anti-avoidance tax (BEAT) (December 14, 2018)
GW/IRS 31st Annual Institute on Current Issues in International Taxation
Eversheds Sutherland (US) Partner Saren Goldner presented on the BEAT (base erosion and anti-avoidance tax) panel at the GW/IRS 31st Annual Institute on Current Issues in International Taxation on ...
Captive Insurance Tax Forum (October 29-30, 2018)
Eversheds Sutherland (US) Partner Saren Goldner presents at the Captive Insurance Tax Forum in Chicago, Illinois, on October 29-30, 2018, on the following panels:Potential Tax Benefits of an ...
Webcast: Section 953(d) Elections - The Election Process May Not Be as Easy as It Appears (August 16, 2018)
American Bar Association
Eversheds Sutherland (US) Partners Bruce Wright and Saren Goldner present on the ABA's Captive Insurance Committee webcast Section 953(d) Elections - The Election Process May Not Be as Easy as It ...
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 ...
Publications
“I thoroughly enjoy working with the U.S. international tax rules. Most of my work involves helping non-U.S. insurance companies or investors in those companies navigate the U.S. tax rules.”
Legal Alerts
Reserving Judgment-New proposed regulations issued on computation and reporting of life insurance reserves (April 15, 2020)
The Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) recently published a notice of proposed rulemaking (Proposed Regulations) regarding the computation of life insurance ...
OECD recognizes legitimacy of captive insurance (February 24, 2020)
On February 12, 2020, the Organisation for Economic Co-operation and Development (OECD) released a report on “Transfer Pricing Guidance on Financial Transactions.” One chapter of the report deals ...
Treasury and the IRS release guidance regarding the repeal of Section 958(b)(4) (October 14, 2019)
The Tax Cuts and Jobs Acts (TCJA) repealed 958(b)(4) of the Code, which prevented downward attribution of stock ownership from a foreign person to a US person. That repeal has resulted in many ...
IRS issues simplified procedures for insurance companies to change methods of accounting to comply with amended Section 846 (August 8, 2019)
The Internal Revenue Service (IRS) recently released two revenue procedures that relate to the implementation of accounting method changes as a result of the revisions to Section 846 of the Internal ...
Long-awaited passive foreign investment company proposed regulations - focus on insurance (July 15, 2019)
On July 11, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued comprehensive proposed regulations on passive foreign investment companies (PFICs) that ...
IRS and Treasury issue final regulations on discounting unpaid losses (June 24, 2019)
The Internal Revenue Service (IRS) and the Treasury Department (Treasury) have issued final regulations that address amendments to the rules for discounting unpaid losses pursuant to Section 8461 ...
LB&I announces new campaigns - Related-party service companies, offshore private banking and loose-filed Forms 5471 (April 25, 2019)
On April 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced three new compliance campaigns. The campaigns focus on: Transfer pricing ...
The Last Piece of the Puzzle-the Section 250 Proposed Regulations (March 12, 2019)
Public Law 115-97 (the Tax Cuts and Jobs Act) added a new foreign income inclusion rule for global intangible low-taxed income (GILTI) under section 951A. The Tax Cuts and Jobs Act also added section ...
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 ...
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, ...
Articles
Washington State Continues To Assess Captive Insurance Companies (March 5, 2020)
Captive Insurance Company Reports
In this article for Captive Insurance Company Reports, Eversheds Sutherland Partners Bruce Wright and Saren Goldner discuss that the Washington Office of the Insurance Commissioner (OIC) has made it ...
New York Supreme Court Appellate Division Rules on Premium Deduction (August 1, 2019)
Captive Insurance Company Reports
In this article for Captive Insurance Company Reports, Eversheds Sutherland attorneys Bruce Wright, Saren Goldner and Kristan Rizzolo explain the results of the New York Supreme Court ruling on ...
Treasury's Proposed Regulations on the PFIC Rules Insurance Exception (July 16, 2019)
Captive.com
Treasury has issued proposed regulations on the insurance exception to the passive foreign investment company rules. This article focuses on only one of the aspects of the regulations, albeit a very ...
Pooling - An Analysis of Best Practices (March 2019)
Captive Insurance Company Reports
Over the course of the last year, particularly in connection with the first and second micro-captive cases issued by the Tax Court, questions have arisen about the validity of “pooling arrangements.” ...
International Regulatory and Legislative Update (March 2019)
Captive Insurance Company Reports
Two sets of proposed regulations published December 13, 2018, clarify the application of the base erosion and anti-base tax (BEAT) and amended the Foreign Account Tax Compliance Act (FATCA) ...
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 ...
New NJ Direct Placement Tax Decision (August 2018)
Captive Insurance Company Reports
In this article for Captive Insurance Company Reports, Eversheds Sutherland attorneys Bruce Wright and Saren Goldner offer their views on the new New Jersey state taxes.
Tax Court Issues in Small Insurance Company Case (August 2018)
Captive Insurance Company Reports
On June 18, 2018, the US Tax Court issued its opinion in Reserve Mech. Corp. v. Commissioner, holding for the Internal Revenue Service (IRS) in concluding that Reserve Mechanical Corp. was not an ...
953(d) Elections: A Real Problem or Is the IRS Making Them a Problem? (June 2018)
Captive Insurance Company Reports (CICR)
In their article for CICR, Eversheds Sutherland attorneys P. Bruce Wright and Saren Goldner offer their thoughts on 953(d) elections for captives and reveal some surprising insights surrounding ...
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 ...
Books
Chapter 6.1: Tax Implications of Risk Financing (November 14, 2019)
Risk Financing, published by the International Risk Management Institute.
In Risk Financing, a reference book explaining the various risk finance options for any organization's liability and workers compensation risks, Eversheds Sutherland Partners Bruce Wright and Saren ...
Chapter 4: US Taxation of Non-US Captives (Spring 2018 )
Captive Insurance Deskbook for the Business Lawyer - published by the American Bar Association
In Captive Insurance Deskbook for the Business Lawyer, a book to help lawyers decipher the intricacies of captive insurance, Eversheds Sutherland Partners P. Bruce Wright and Saren Goldner ...
Appendix: The Base Erosion Anti Abuse Tax (BEAT)-Overview (Spring 2018)
Captive Insurance Deskbook for the Business Lawyer - published by the American Bar Association
In Captive Insurance Deskbook for the Business Lawyer, a book to help lawyers decipher the intricacies of captive insurance, Eversheds Sutherland Partners P. Bruce Wright and Saren Goldner ...
