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