Saren Goldner focuses her practice on international tax, insurance, reinsurance and insurance tax issues.
This includes insurance characterization, structuring of non-US operations, captive insurance companies, reinsurance facilities and swaps, investor tax issues in non-US insurance companies and other insurance specific tax issues, including state taxation of insurance companies and insurance premiums.
She advises on public and private securities offerings, including securitizations, catastrophe bonds and other insurance-linked structures, as well as the structuring of international insurance operations, including the application of tax treaties, US trade or business issues, withholding tax, FET, FATCA, CFC, PFIC and other tax issues arising as a result of cross-border operations. She also advises on the formation and operation of captives and cell companies and tax exempt issues.
Saren has extensive experience handling the full range of tax issues applicable to insurance companies and captive insurance companies as well as their investors and insureds/reinsureds, and the complex insurance regulatory issues applicable to captive operations as well as reinsurance agreements and Regulation 114 trusts.
Her experience also includes providing guidance on the transactional taxation of insurance premiums, including self-procurement taxes and advising on proposed assessments, including structuring and risk mitigation strategies.
She also advises on reinsurance agreements, offering materials, shareholder agreements and other insurance related contracts, and helps develop structured financial products.
Prior to joining Eversheds Sutherland (US), Saren served as a judicial clerk for the Honorable Herbert L. Chabot at the United States Tax Court.
She advises on public and private securities offerings, including securitizations, catastrophe bonds and other insurance-linked structures, as well as the structuring of international insurance operations, including the application of tax treaties, US trade or business issues, withholding tax, FET, FATCA, CFC, PFIC and other tax issues arising as a result of cross-border operations. She also advises on the formation and operation of captives and cell companies and tax exempt issues.
Saren has extensive experience handling the full range of tax issues applicable to insurance companies and captive insurance companies as well as their investors and insureds/reinsureds, and the complex insurance regulatory issues applicable to captive operations as well as reinsurance agreements and Regulation 114 trusts.
Her experience also includes providing guidance on the transactional taxation of insurance premiums, including self-procurement taxes and advising on proposed assessments, including structuring and risk mitigation strategies.
She also advises on reinsurance agreements, offering materials, shareholder agreements and other insurance related contracts, and helps develop structured financial products.
Prior to joining Eversheds Sutherland (US), Saren served as a judicial clerk for the Honorable Herbert L. Chabot at the United States Tax Court.
Latest Insights
Latest News
- Represented Automobile Club of Southern California in the acquisition of 50% of Motor Club Insurance Company and in the formation of a related joint venture.
- Tax Update, September 27, 2023, South Carolina Captive Insurance Association Annual Conference
- Update on Federal and State Tax Issues and Significance of Exposure Units in Analyzing Risk Distribution, May 10, 2023, North Carolina Captive Insurance Association Annual Conference
- Focus Points: Procedural Overview of the IRS Audit Process and Cat Bonds, Parametric Coverage and Other ILS, March 22, 2023, 2023 Captive Insurance Tax Forum
- Use of Captive Surplus and Basics of Captive Tax Compliance, March 22, 2023, 2023 Captive Insurance Tax Forum
- Overview of Cell, Series and Rent-a-Captives, March 22, 2023, 2023 Captive Insurance Tax Forum
- Insurance Characterization for Federal Tax Purposes; Entity Selection and Program Structure, March 21, 2023, 2023 Captive Insurance Tax Forum
- Tax and Regulatory Considerations for Non-US Captives, March 21, 2023, 2023 Captive Insurance Tax Forum
- Risk Distribution: Siblings, Strangers and Exposure Units, Pools, Treaties and Other Third-Party Risks, March 21, 2023, 2023 Captive Insurance Tax Forum
- Redomiciling of Captive Arrangements, March 21, 2023, 2023 Captive Insurance Tax Forum
- Captive Taxation, May 4, 2022, CIA NC Annual Conference
- International Tax Basics, March 9, 2022, Insurance Tax Webcast – Session 4
- P&C Companies and Captive Tax Basics, January 26, 2022, Eversheds Sutherland Insurance Tax Webcast
- Insurance Tax on the Horizon, January 13, 2021, Eversheds Sutherland January Outlook Webcast Series
- 2021 Tax Outlook Webcast Series, January 5-15, 2021
- Captive Insurance Tax Forum, February 25-26, 2020
- Evolution of Captive Taxation: Recent Developments & Best Practices, December 12, 2019, Vermont Captive Insurance Association (VCIA)
- Chapter 6.1: Tax Implications of Risk Financing, November 14, 2019, Risk Financing, Published by the International Risk Management Institute
- Captive Insurance Tax Forum, October 28-29, 2019
- How the New Proposed Passive Foreign Investment Company Regulations Affect Captives, September 26, 2019, ABA Business Law Section’s Captive Insurance Committee
- Direct Procurement, Related State Tax Issues and Federal Excise Taxes, September 17, 2019, Minnesota Chapter of the Risk and Insurance Management Society (RIMS)
- Captive Insurance Tax Forum, February 25-26, 2019
- Base Erosion and Anti-Avoidance Tax (BEAT), December 14, 2018, GW/IRS 31st Annual Institute on Current Issues in International Taxation
- Captive Insurance Tax Forum, October 29-30, 2018
- Webcast: Section 953(d) Elections – The Election Process May Not Be as Easy as it Appears, August 16, 2018, American Bar Association
Books
- Chapter 4: US Taxation of Non-US Captives, Spring 2018, Captive Insurance Deskbook for the Business Lawyer – Published by the American Bar Association
- Appendix: The Base Erosion Anti Abuse Tax (BEAT)—Overview, Spring 2018, Captive Insurance Deskbook for the Business Lawyer – Published by the American Bar Association
- Recognized by Chambers USA: Guide to Leading Business Lawyers in the area of tax (2019-2025)
- Recognized by The Legal 500 United States in the area of international tax (2020, 2022, 2024-2025)
- Recognized by the Lawyers Alliance for New York with the Cornerstone Award, New York’s highest business law pro bono honor (2023)
- Named to Best Lawyers in the area of insurance law (2023-2026) and tax law (2024-2026)
- District of Columbia
- New York
Honorable Herbert L. Chabot, United States Tax Court
- J.D., State University of New York at Buffalo Law School
- B.A., summa cum laude, University of Massachusetts