Kirk Van Brunt is a tax partner with over 25 years of experience with the taxation of financial institutions and products, with a particular focus on insurance companies and insurance products. Within the insurance arena, Mr. Van Brunt has substantial experience with bank/corporate owned life insurance (BOLI/COLI) and is very active within the life settlement and structured settlement industry. Mr. Van Brunt also has substantial experience in the tax treatment of asset-backed securities and derivative financial instrument, and in-bound tax issues for the foreign investor. Mr. Van Brunt is widely published and frequent speaker at industry conferences and seminars.
Education
- J.D., cum laude, Harvard Law School, 1985
Harvard Law Review - B.A., magna cum laude, Northwest Nazarene College, 1980
Bar Admissions
- Massachusetts, 1985
- District of Columbia, 1986
Admitted To Practice
- U.S. Court of Federal Claims
- U.S. Court of Appeals for the Federal Circuit
- U.S. Tax Court
- D.C. Court of Appeals
Representative Experience
- Insurance Products: Specific focus on bank- and corporate-owned life insurance, private placement variable life insurance and annuities, section 7702 and 7702A issues.
- Insurance Company Taxation: Reserving, acquisitions, “DAC” tax, “Subpart F” and “PFIC” issues.
- Structured Settlements: section 130 and section 5891 issues; “nonqualified” structured settlements; structuring of attorneys fees; constructive receipt and section 104(a)(2) issues.
- International Taxation: Inbound and outbound investment transactions; PFIC & CFC rules; treaty planning; tax withholding.
- Taxation of Financial Products: Taxation of structured products and other derivatives, asset backed securities, capital markets transactions.
- Taxation of Equity Funds: The organization and taxation of regulated investment companies, REMICs, and private equity funds.
- Partnership Taxation: Taxation of partnership entities under Subchapter K; taxation of allocations/distributions; drafting of partnership/LLC agreements.
Publications & Presentations
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Practice Member,
"Regulatory & Transactional Insurance: The Guidance You Need,"
Locke Lord Brochure
(February 2012)
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Co-Author,
"
Locke Lord QuickStudy: Legislation Introduced Affecting Taxation of Life Settlement and Similar Transactions
,"
Locke Lord
(February 8, 2012)
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Author,
"
Locke Lord QuickStudy: Important IRS Private Letter Ruling on Bank-Owned Life Insurance Policies
,"
Locke Lord
(January 11, 2012)
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Author,
"Locke Lord QuickStudy: Foreign Affiliate Reinsurance,"
Locke Lord
(October 17, 2011)
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Author,
"Locke Lord's QuickStudy: Employer-Owned Life Insurance – IRS Rules on 1035 Exchanges and Code Section 264(F),"
Locke Lord
(March 3, 2011)
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Author,
"Locke Lord's QuickStuy: White House Releases 2012 Budget - Tax Proposals for the Insurance Industry,"
Locke Lord
(February 14, 2011)
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Author,
"Client Alert: New Budget Contains Tax Proposals Targeting Insurance,"
Locke Lord
(February 1, 2010)
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Co-Author,
"Client Alert: Legislation Introduced Targeting Related Party Reinsurance,"
Locke Lord
(August 6, 2009)
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Co-Author,
"Client Alert: The IRS Issues Important Guidance on Life Settlement Transactions,"
Locke Lord Bissell & Liddell LLP
(May 5, 2009)
Professional History
- Partner, Locke Lord LLP
- Partner, Davis & Harman LLP, Washington, D.C. (1997 - 2008)
- Senior Associate, Davis & Harman LLP, Washington, D.C. (1994 - 1996)
- Senior Associate, Cleary, Gottlieb, Steen & Hamilton, Washington, D.C. (1990 - 1994)
- Associate, Davis & Harman LLP (1987 - 1990)
- Associate, Patton, Boggs & Blow, Washington, D.C. (1985 - 1986)
Professional Affiliations & Achievements
- Member, Federal Bar Association
- Member, American Bar Association
- Member, Legal Committee of the National Structured Settlement Association
- Member, Association of Life Insurance Counsel
- Chair, Committee on Insurance Companies, Tax Section, American Bar Association (2006 - 2008)
- Vice Chair & Secretary, Committee on Insurance Companies, Tax Section, American Bar Association (2002 - 2006)
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