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Title : Tax/erisa Attorney

Location : Florida - Jacksonville
Refer to Job # YBIN786669

Tax / ERISA Attorney The candidate will review/revise/draft tax disclosures for insurance product and mutual fund prospectuses and private placement memoranda. Will negotiate tax provisions in agreements between insurance companies and mutual funds. Review/draft tax provisions for new insurance product designs. Review/revise tax-qualified and IRA endorsements. Address and resolve tax disputes with the IRS regarding compliance with Section 817(h) and other IRC provisions, including the preparation of private letter rulings regarding inadvertent MEC diversification failures and Section 817(h) asset diversification failures. Advise on and develop policies and procedures regarding tax and ERISA compliance as relevant to retirement plans. Advise on whether specific activities, including recommendations to roll over retirement plan assets, constitute the provision of investment advice. Advise on the application of prohibited transaction exemptions to specific situations. Advise on the application of ERISA's fiduciary responsibility and conflict of interest provisions to specific situations. Respond to questions regarding tax information reporting. Respond to questions regarding HIPAA privacy requirements. Review tax provisions of draft buy/sell insurance company agreements. Must have experience in the federal income tax treatment of (1) life insurance contracts, including variable life insurance contracts, modified endowment contracts and corporate owned and bank owned life insurance contracts and (2) annuity contracts issued in connection with qualified plans, IRAs, 403(b) plans, and 457 plans, as well as nonqualified annuities. Experience should include extensive knowledge of asset diversification under Internal Revenue Code Section 817(h) and the regulations thereunder, regulated investment company diversification and investor control. Experience also should include knowledge of ERISA's fiduciary, party-in-interest, reporting and disclosure and prohibited transaction provisions involving retirement products and service offerings.

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