FacultyFaculty/Author Profile
Susan E. Seabrook

Susan E. Seabrook

Eversheds Sutherland (US) LLP

Washington, DC, USA


Susan Seabrook provides innovative solutions and strategies to a wide variety of complex tax issues faced by insurance companies, reinsurers, financial institutions and other large multinational corporations. With more than 25 years of experience, she advises on highly technical Internal Revenue Service (IRS) procedural, controversy and tax litigation matters, representing clients in all phases of examination, audit, discovery and administrative appeals.

With clients that span a variety of industries—including healthcare, finance, energy, life sciences and leasing—Susan regularly counsels on large-scale mergers and acquisitions, insurance and reinsurance transactions (life and non-life), Subchapter L issues, captives, general corporate transactional tax planning, structuring and restructuring, and tax risk assessments.

Prior to entering private practice, Susan worked for a Big Four accounting firm and the IRS Office of Chief Counsel where, for nearly 10 years, she served as a senior trial attorney and attorney advisor in the insurance branch of the Financial Institutions and Products division. As a senior trial attorney, she tried many cases and served as counsel to an IRS Exam team in a joint audit with the Japanese National Tax Administration.

A widely respected thought leader, Susan is a frequent speaker and panelist on IRS practice, controversy and tax litigation matters, and appears regularly before industry groups and at insurance tax conferences.

Awards and Rankings:

  • Recognized by The Legal 500 United States in the area of tax controversy (2009-2011, 2014, 2018)
  • Recipient, IRS Special Act Award (1994, 1995, 1996)
  • Recipient, IRS Performance Award (1997, 1999)

Professional Activities:

  • Member, American Bar Association, Section of Taxation
  • Member, Federal Bar Association, Section of Taxation
  • Member, National Association of Women Lawyers
  • Vice President and Secretary, Insurance Tax Conference
  • Master, Edgar Murdock (Tax Court), American Inns of Court
Susan E. Seabrook is associated with the following items:
Treatise Chapters  Treatise Chapters Insurance Tax Issues in Mergers and Acquisitions: Identifying and Preserving Value and Avoiding Subchapter L Surprises - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
Web Segment  Web Segment Exploring the Limits of the Evolving Economic Substance and Business Purpose Doctrines and Related Penalty and Ethics Issues - Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2018, Monday, October 22, 2018
MP3 Audio  MP3 Audio Exploring the Limits of the Evolving Economic Substance and Business Purpose Doctrines and Related Penalty and Ethics Issues - Exploring the Limits of the Evolving Economic Substance and Business Purpose Doctrines and Related Penalty and Ethics Issues, Monday, October 22, 2018
Transcripts  Transcripts Exploring the Limits of the Evolving Economic Substance and Business Purpose Doctrines and Related Penalty and Ethics Issues - Exploring the Limits of the Evolving Economic Substance and Business Purpose Doctrines and Related Penalty and Ethics Issues, Monday, October 22, 2018
MP4 - Mobile Video Seg  MP4 - Mobile Video Seg Exploring the Limits of the Evolving Economic Substance and Business Purpose Doctrines and Related Penalty and Ethics Issues - Exploring the Limits of the Evolving Economic Substance and Business Purpose Doctrines and Related Penalty and Ethics Issues, Monday, October 22, 2018
On-Demand Web Programs  On-Demand Web Programs Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2018, Friday, October 26, 2018, New York, NY
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