A large practice area for us is advising. For example, we have:

• Advised on the appropriate level of tax reserves;
   
• Submitted comments to the Treasury Department on matching premium acquisition expenses with related gross premium accelerated under the earned premium regulations under I.R.C. § 832;
   
• Processed and developed requests for global interest netting;
   
• Developed a deferred compensation program for independent contractor agents to create incentives for marketing;
   
• Served as tax counsel on Congressional legislative projects, advised on technical tax issues and monitored legislative developments;
   
• Advised on the issues involved in obtaining and retaining tax-exempt status for nonlife insurance companies under I.R.C. § 501(c)(15);
   
• Advised on information reporting and withholding obligations and penalties with respect to payments under insurance products, foreign transactions and application of tax treaties;
   
• Advised on the federal excise tax under I.R.C. § 4371;
   
• Advised companies of reporting, listing and registration requirements on purported tax shelters; and
   
• Submitted comments on the impact of I.R.C. § 409A on deferred compensation arrangements of insurance companies; and
   
• Served as tax counsel for tax-exempt organizations, providing tax advice on various issues including avoiding UBIT and adopting tax-efficient procedures.