Tax Indemnity Insurance
Tax Indemnity Insurance
A variety of different parties, including private equity funds and publicly listed corporations, use these products to preserve the expected tax treatment as it’s filed with the tax authority. Typical examples of tax positions that may qualify for this coverage include the tax-neutral status of an internal restructuring or an M&A transaction, and the availability of withholding tax exemptions on dividend or interest payments.
We are able to offer insurance for tax risks arising in a variety of countries, including the United States, Canada, Australia, as well as countries across Europe, Asia and Latin America.
The policy protects the insured against any tax loss (including associated interest, certain penalties and contest costs, as well as any necessary gross-up to cover tax on the receipt of any insurance proceeds).
The tax underwriting team is experienced and has extensive knowledge of the market across multiple jurisdictions. VALE’s disciplined and long-term underwriting approach means that we are regarded as a leading market within the industry.
Prior to joining VALE, Peter was Counsel at a large international New York law firm. While in private practice, Peter focused primarily in the fields of taxation, closely-held businesses, and exempt organizations. Peter’s experience also includes general corporate and partnership transactions. Peter’s tax practice includes federal tax matters relating to entity selection, formation, transfer of ownership, and operational issues. He also specializes in the formation of off-shore investment vehicles designed to minimize exposure to U.S. taxation.
Peter received his B.A. in history and sociology from the University of Vermont and his J.D. from the George Washington University Law School.
Peter is a member of the bar in New York and Massachusetts and is admitted to appear before the U.S. Tax Court and several U.S. federal courts.
Mark Hale is a Director and Head of Tax. Mark is a tax attorney specializing in international M&A and joined VALE from his role as International Tax Counsel for General Electric (London). Mark has analysed tax risks for GE Capital and other GE business lines and led teams of external tax advisors in over 40 different countries. Before GE, Mark practiced US tax law with Morgan Lewis (London), Baker & McKenzie (Zurich) and Allen & Overy (London) and advised private equity and corporate clients. Mark holds a Tax LL.M. from New York University (New York) and J.D. and undergraduate degrees from Georgetown University (Washington, DC). Mark is a member of the New York State Bar.