Realizing Certainty through Tax Insurance

Today’s tax structures and their legal, financial and business implications are material and complex. The impact of an unexpected tax challenge can significantly compromise the value of a deal, a tax credit investment, or tax planning.

Tax insurance is designed to protect you in the event that an investment or tax position fails to qualify for its intended tax treatment. This can cover losses including taxes payable, interest and penalties, and gross-up amounts for tax due on insurance proceeds. It can also cover contest costs tied to the defense of the insured position.

Similar in effect to a private letter ruling, tax insurance brings certainty to taxpayers regarding the treatment of their US federal, state, local, and foreign taxes positions. Tax insurance is an effective and economic means of protecting against an unexpected or significant impact on financial statements and earnings. Aon clients that have relied upon tax insurance include private equity sponsors and their portfolio companies, Fortune 500 companies and other participants in global M&A and financial transactions.

Tax opinion / tax credit insurance

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Aon’s Tax Insurance team delivers unparalleled depth of knowledge and experience to effectively guide clients in protecting against an adverse tax ruling that can compromise the value of a transaction, a tax-equity position, or earnings. Our broad range of tax insurance solutions addresses many tax risks that deal professionals, corporate tax professionals, and tax credit investors face.

Gary Blitz
Office: New York
O: (212) 441-1106 | M: (301) 704-4640 |
Gary P Blitz is Co-CEO of Aon Mergers & Acquisitions and Transaction Solutions, with primary responsibility for Tax Insurance and other Transaction Solutions. The Transaction Solutions practice is the leading insurance broker of Transaction Liability Insurance, including Representations and Warranties Insurance (aka M&A Insurance), Tax Insurance and bespoke transactional insurance solutions. The Tax Insurance practice specializes in the placement of tax insurance programs for M&A transactions, tax credit investments and corporate tax risk management. Throughout Gary’s career, he has been a leader in the tax and transactional insurance business and played an instrumental role in the development of Representations and Warranties Insurance and Tax Insurance and the growth of transaction liability insurance generally. Gary joined Aon in 2004 after a twenty-year legal career at firms, including Mintz Levin and predecessors of DLA Piper and Katten Muchin Rosenman. Gary began his career as a tax lawyer and acted as legal counsel to U.S., London and international insurers, and was a nationally recognized expert in the insurance of financial and transactional risks. Gary also founded ML Insurance Strategies, the insurance brokerage affiliate of Mintz Levin, and Kingswood Group, a tax credit insurance underwriter. Gary graduated from the University of Michigan School of Business Administration with a B.B.A. with Distinction and from New York University School of Law with a J.D. He is a member of the New York State and District of Columbia Bars, and a licensed property and casualty insurance broker in New York and other states. Gary previously served on the Board of Directors of Adoptions Together Inc., a Maryland not-for profit, in various capacities.

Daniel Schoenberg
Senior Managing Director
Office: New York
O: (212) 441-2033 | M: (917) 361-3478 |
Dan Schoenberg joined Aon in June 2013. Dan was most recently a Director at Deutsche Bank and served as tax counsel for the bank. Prior to joining Deutsche Bank, Dan was a senior tax associate at the international law firms Fulbright & Jaworski LLP (now Norton Rose Fulbright LLP) and Andrews Kurth LLP. Dan has advised on U.S.-based and European-based acquisitions and divestitures with total values in excess of $15 billion. Representative transactions include Deutsche Bank’s staged acquisition of Deutsche Postbank, a leading global industrial company’s sales of the assets and stock of its U.S. and foreign subsidiaries and Code Section 355 spin-offs, and the shelved 2008 takeover of Bell Canada Enterprises (which would have been the largest leveraged buyout in history). Dan also initiated, designed, negotiated and executed tax equity investor acquisitions of refined coal production facilities generating potentially $500 million of tax credits for Deutsche Bank.

Jill Kerxton
Managing Director
Office: Washington, DC
O: (202) 570-3222 | M: (301) 785-9239 |
Jill joined the ATS team as a Senior Vice President. Jill has worked in the tax and transactional insurance business throughout her career. Prior to joining Aon, Jill enjoyed a twenty-year legal career where she was a partner at firms, including Mintz Levin and predecessors of DLA Piper and Katten Muchin Rosenman. As co-leader of the Financial Risks Practice, Jill became a nationally recognized expert in the insurance of financial and transactional risks, such as M&A insurance, insurance programs covering tax and regulatory risks, litigation buyouts, environmental insurance and credit enhancements and played an instrumental role in the development of Tax insurance, R&W Insurance and other transactional insurance products. Jill began her career as a tax lawyer and acted as legal counsel to U.S., London and international insurers, many of which regularly underwrite financial risks. Today, she advises clients purchasing such insurance programs.

David McCann
Office: London
O: +44 (0) 20 7086 7071 | M: +44 (0) 7826 901486 |
David leads Aon’s EMEA tax insurance team. He has arranged tax insurance solutions for private equity, REIT and strategic clients operating in a range of EU countries. Prior to joining Aon, David spent nearly a decade at Clifford Chance in London, advising on the tax aspects of cross-border M&A, reorganisations, finance and contentious matters.

Jessica Harger
Senior Vice President
Office: New York
O: (212) 441-2443 | M: (914) 572-2422 |
Jessica joined the Aon’s Transaction Solutions team as part of its Tax Insurance Practice. Prior to joining the team, she worked as a tax consultant in “big four” accounting, most recently in EY’s Transaction Tax group. Jessica began her career at PwC, advising financial services clients and focusing on international tax issues in M&A transactions. She has advised on both private equity and strategic corporate deals from the buy-side and sell-side, with total value in excess of $10 billion. Jessica has experience in all stages of the transaction life cycle, including strategic analysis of opportunities, development of financial and tax structures, due diligence and negotiation of sale and purchase agreements, and post-transaction implementation.

Osmel Cuan
Vice President
Office: San Francisco
O: (415) 402-6310 | M: (415) 214-3934 |
Osmel “Ozzy” Cuan is a Vice President with Aon’s Transaction Solutions team and focuses on tax insurance. Prior to joining Aon, Ozzy was a Manager in Ernst & Young’s Transaction Advisory Services (M&A Tax) group, where he provided tax structuring and transaction advice to corporate and private equity clients. He began his career as a tax attorney with Akerman LLP in New York and Florida, advising multinational companies and high net-worth individuals on international tax matters. He holds a JD from Fordham University, an LLM in taxation from New York University and is fluent in Spanish.

Corey Lewis
Vice President
Office: New York
O: (212) 479-3627 | M: (347) 291-4921 |
Corey Lewis joined Aon in June 2015. Corey was most recently an Associate in the International Tax Services: Financial Services / Real Estate division in the New York office of PricewaterhouseCoopers. At PwC, Corey focused primarily on the tax structuring of international real estate investments. Corey graduated from The University of Texas School of Law and the University of Michigan.

Neil Kratz
Office: London
O: +44 (0) 20 7086 0247 | M: +44 (0) 7747 461910 |
Neil Kratz joined Aon in 2017. Neil was most recently a tax consultant at Deloitte in Luxembourg where he advised clients on the tax aspects of cross-border M&A and restructuring matters. Neil holds an LLM in Tax Law and is fluent in German. Neil’s tax experience allows him to represent Aon’s clients effectively when placing complex tax risks into the insurance market.