Ms. 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, federal excise tax (FET), Foreign Account Tax Compliance Act (FATCA), controlled foreign corporation (CFC), passive foreign investment company (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.
Ms. Goldner 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), Ms. Goldner served as a judicial clerk for the Honorable Herbert L. Chabot at the United States Tax Court.
