International Life Insurance



David D. Whelehan, JD, CLU, ChFC, is President and CEO of AG Transnational, Ltd. (BVI), a company dedicated to international life insurance. AGT offers consulting services to insurance carriers, banks, trust companies and professional firms. It also is a wholesale distributor of international insurance products to distribution channels, such as financial and insurance organizations. He's active in the International Bar Association and in industry organizations on this subject, being a frequent speaker and author. Dave has over 35 years of legal, tax, marketing and insurance management experience, having started international insurance companies from Europe to Asia. A graduate of Holy Cross College, George Washington University Law School and the American College, he is a member of the International, American, Virginia and Connecticut Bar Associations.
AGT is domiciled in the British Virgin Islands and has a US correspondence address of: 36 North New York Ave. Huntington, NY 11743 USA. Phone 001 631 549-2324. Fax 001 631 549-2350. E-mail: dwhelehan@agtrans.com

Joel J. Karp is the managing partner in the Coral Gables, Florida law firm of Karp & Genauer, P.A., a tax and transactional boutique law firm. He is responsible for consulting with clients and the firm's personnel on international tax and business planning and compliance, as well as estate tax.

Born in Brooklyn, New York, he received his B.A. degree from Columbia College and his LL.B from Columbia University Law School. He is admitted to practice in New York and Florida.

He is a member of the International, American, New York and Florida Bar Associations (Board Certified by the Tax Section of the Florida Bar Association), International Tax Planning Association, Society for Tax and Estate Planners (S.T.E.P.), the International Law Advisory Committee and the Foreign Tax Advisory Committee of the Florida Bar Association; a Council member of the International Fiscal Association (U.S.A. Branch) and Regional Vice President of the Southeastern Region, and has served as Adjunct Professor in the Tax Program at Florida International University.

Joel Karp is a frequent speaker at programs sponsored by both the Tax Section and the International Section of the Florida Bar, the International Tax Planning Association, S.T.E.P. and IBC USA, and has written several articles published by OFFSHORE INVESTMENT, including Life Insurance and the NRA, Property and Casualty Insurance: Some Niches for Niche Players, and The New World - Tax Free Exchanges of Insurance Contracts, has contributed articles for TRUSTS & ESTATES, including Continued Use of Foreign Trusts in U.S. Tax Planning, June 1998, at 36. He reviews and revises the annual U.S. chapter update for The International Guide to Taxation of Life Assurance and Mutual Funds, MONITOR PRESS LTD. (U.K.), March 1999. His most recently published work was a chapter entitled Operating in the Offshore World, A GUIDE TO INTERNATIONAL ESTATE PLANNING (Jeffrey A. Schoenblum, ed.), ch. 13, American Bar Association Section of Real Property, Probate and Trust Law, 2000.

James A. Walker, Jr is the president of J.A. Walker & Associates, P.C., an Atlanta, Georgia law firm specializing in insurance and international tax and estate planning. Additionally, he is a member of Walker, Black & Co, LLC., an Atlanta, Georgia based insurance company consulting firm. Mr. Walker received his undergraduate degree in history with honors from the University of Virginia, and his law degree with honors from the University of Georgia, including serving on the Georgia Law Review. After graduating law school, Mr. Walker joined the firm Powell, Goldstein, Frazer & Murphy in Atlanta, Georgia, where he would make partner in the tax and estate planning department. Mr. Walker left the firm in 2001 to start J.A. Walker & Associated, P.C., a law firm specializing in international insurance and tax planning, and Walker, Black & Co, a consulting company to insurance companies. He is a frequent author and speaker on international insurance and international tax topics.

Wolfe D. Goodman, Q.C., S.J.D., a partner in Goodman and Carr LLP, Toronto, has practiced since 1949 primarily in the areas of tax law and estate planning. He has written and lectured extensively on estate planning and tax matters for over 40 years. He is the general editor of Goodman on Estate Planning, a quarterly newsletter. He received his SJD degree from the University of Toronto in 1976.
Mr. Goodman can be reached by telephone at 416.595.2620 or at his e-mail address wgoodman@goodmancarr.com.

Sergio Yarritú Gonzalez, Managing Partner of Smart Consulting S.C., Mexico City, specialises in international tax matters.

Marco H. Hernandez Tracey practices in the areas of finance and banking at Carlsmith Ball S.C. Mexico City.

Ana Cláudia Akie Utumi was admitted to the bar in 1996, in São Paulo, Brazil. Education: University of São Paulo School of Law (LL.B.,1994); Business Administration, Getúlio Vargas Foundation, School of Business Administration (1988-1992). MBA in Finance and Capital Markets, Brazilian Institute of Capital Markets (IBMEC - 1995-1996). Master in Tax Law, Pontifícia Universidade Católica de São Paulo ("PUC-SP", 2001, Theme: "Transfer Pricing in Brazil"). Assistant Professor in PUC/SP, for the post-graduation course of International Tax Law. Visiting professor at Getúlio Vargas Foundation School of Law for the Course "Economy and Corporate Law". Visiting professor at University of São Paulo School of Economy and Business ("FEA/USP"), for the Course "MBA in Finance and Risk Management".

Currently partner at Tozzini, Freire, Teixeira e Silva Advogados, in charge of the Tax Consulting Department in the São Paulo office (www.tozzini.com.br). Worked for Coopers & Lybrand, Tax Department (1992-1996). Former associate lawyer at Mattos Filho, Veiga Filho, Marrey Jr., Moherdaui e Quiroga Advogados, coordinating the areas of Taxation of Financial and Capital Markets, Taxation of Structured Transactions (Corporate, Banking and Capital Markets transactions), International Taxation and Tax Planning (1996-2000).

Author of articles published in the books "Taxes and Transfer Price", coordinated by Prof. Valdir de Oliveira Rocha (Dialética, 1997), "Tax Planning - Theory and Practice", vol. 2, coordinated by Prof. Valdir de Oliveira Rocha (Dialética, 1998); "Taxes and Transfer Price", vol. 2, coordinated by Prof. Luís Eduardo Schoueri (Dialética, 1999), and articles "Non-imposition of tax on foreign currency exchange transaction on renewal of foreign loan without transference of funds" (Revista de Direito Tributário, v. 70, 1998) and "Imposition of tax on credit transactions for non-financial credit operations" (RDT, v. 76, 1999). Member of Brazilian Institute of Tax Law, Brazilian Association of Tax Consultants and Institute of Tax Researches.

Thomas F. Morante is a partner in the law firm Jones Walker, a national law firm. Mr. Morante specializes in corporate, insurance and international law with emphasis in life insurance/annuities, investment company products, pensions, securities offerings, M&A, and international dispute resolution, with a geographic concentration on Latin America and Europe.

Mr. Morante received his LL.M. in international law from Georgetown University Washington DC, and his J.D from American University, Washington, DC. Mr. Morante has been practicing law for over 20 years. tmorante@joneswalker.com
www.joneswalker.com

Philippe Juilhard was born in France in 1961. He is a partner of CMS Bureau Francis Lefebvre and a Member of the American Bar Association.
He graduated from Paris I and Paris II University (France) and Georgetown University (USA). He specializes in international tax law.

Juilhard joined Bureau Francis Lefebvre in 1988. From April 1994 to April 1997, he worked in London as manager of the UK office of Bureau Francis Lefebvre.

He has contributed to various law and finance magazines (e.g. RJF, IBFD, Option Finance) with articles on international corporate and individual taxation.

He has spoken at the University of Strasbourg and Aix-Marseille, and a number of tax conferences.
In 2001, he published a book on the international taxation of private clients.

Tel. : 01.47.38.56.14 Fax : 01.47.45.80.46
e.mail: ph.juilhard@bfl-avocats.com
www.bfl-avocats.com

Sonja Klein is a Partner of Baker & McKenzie. She jined Baker & McKenzie's Frankfurt office in 1996 and was admitted to the bar in 1994.

Sonja Klein is a member of the Tax Practice Group of the Frankfurt office of Baker & McKenzie and of the European Tax Practice Group of Baker & McKenzie.

While she represents clients in a variety of tax and corporate matters, the focus of her practice lies in tax planning for multinationals as well as estate planning for high net worth individuals. In this context she advises in particular on tax optimized estate planning structures for German residents and for foreign residents with German assets. Beyond that, she also focuses on tax efficient step-up structures, optimization of thin capitalization planning, transfer pricing and business reengineering such as implementing commissionaire structures.



Paolo Ludovici joined Maisto e Associati in 1991. He works with international tax planning and reorganisations.
His expertise includes tax planning for high net worth individuals, structured finance, investment funds and employment benefit schemes.
He has published a large number of works on these subjects. Very early on, he became a regular writer for Italy's leading financial newspaper (Il Sole 24 Ore), as well as other tax reviews and magazines. He is co-author of the Investment Funds section on Italy by the IBFD.
He often speaks at tax conferences and lectures on tax matters for specialist courses at university level and for various other organisations.

Tel. +39.02.776931 Fax +3902.77693300
Paolo Ludovici
Maisto e Associati - Seat of Milan
P.zza F. Meda, 5
20121 MILANO
Tel. 02.776931
Fax 02.77693300
Maisto e Associati - Branch of London
Royex house - Aldermanbury sq.
LONDON EC2V 7HR
Tel. 020.77266560
Fax 020.77266561
e-mail: p.ludovici@maisto.it

Francesco Di Carlo worked for Studio Pirola, Pennuto, Zei & Associati (Member Firm of PricewaterhouseCoopers) from 1996 to 1999; in 1999, he joined Annunziata e Associati.

He acts for a large number of Italian ad international financial institutions, investment companies, investment banks and insurance companies, as well as many private corporations. He is specialised in financial markets and banking law and regulations. In addiction, he provides specialistic advice to insurance companies, principally devoted to Italian and EU regulation.

He has published works on financial services and speaks at conferences and lectures on the above mentioned subjects for specialist courses at university level and for other organisations.

E-mail: f.dicarlo@studioannunziata.com
Tel. +39.02.29061151
Fax +39.02.29061024

Adolfo Rovira del Canto has an Honours Degree in Economics and Business Administration, and is a qualified Insurance Actuary.
He is a Partner in the Cuatrecasas banking and insurance Group with wide experience in giving tax advice to financial and insurance entities, as well as in designing tax profiles for products. He is also a Professor for the Master's degree in Tax Consultancy at the International University of Catalonia, and for the Master's degree in Tax Consultancy at the Pompeu Fabra University and the Polytechnic University of Catalonia.
Contact tel. + 34 93 290 5445

Miles Dean is a lawyer who has specialises in international tax. Miles joined IFS in 1997 and is responsible for all new client issues and developing new markets and has a particular interest in the use of life assurance in international tax planning. He is the co-author, with Roy Saunders, of International Tax Systems and Planning Techniques, published by Gee Publishing which is now in its 42nd release. He also writes frequently for various publishers and publications, including Trusts & Trustees, Tax Planning International Review, TPIR E-Commerce Taxation, and has contributed to Basic International Tax Planning by Roy Rohatgi published by Kluwer Law.




Joseph M. Fong is the Professor of Insurance of the Graduate Institute of Insurance (GII), Feng Chia University (FCU). Prof. Fong's Teaching career with FCU spans almost 25 years during which time he had served as the Dean of the GII for the period of 1979-1990. Most of his teaching experience has been with annuity insurance and financial aspects of life insurance operation .He has been served as an Insurance Advisor over 20 years for Ministers of Taiwan Government. He is an educator and a writer (a dozen books and papers over 100).

Prof. Fong is a Fellow of the Life Management Institute specialized in Pension Planning.

He holds a master degree in business administration from Auburn University.
Email: bus_gins@fcu.edu.tw
Fax: 886-4-2451-2176 Tel: 886-4-2451-725

Mr Masatami Otsuka is of counsel to Jones, Day, Reavis and Pogue (motsuka@JonesDay.com) , a U.S. law firm. He specializes in international taxation. He is a member of the New York Bar Association, the Daini Tokyo Bar Association in Japan, the Japanese Institute of Certified Public Accountants, the International Fiscal Association, and has passed the Uniform CPA examination in the United States. He is a Lecturer of International University of Japan and Ritsumeikan University. He has an LL.B. and LL.M. from Tokyo University.

Mr Ichiro Otsuka is a partner of Blakemore & Mitsuki (otsuka@blakemore.gr.jp), a Japanese law firm in Tokyo. He specializes in international business transactions and international litigation. He is a member of the Daini Tokyo Bar Association in Japan, the New York Bar Association and the International Fiscal Association. He has an LL.B. from Kyoto University and LL.M. from Cornell Law School.

Mr Nakatani is a partner of Anderson Mori (eiichironakatani@andersonmori.com), a Japanese law firm in Tokyo. He specializes in international business transactions, especially international taxation. He is a member of the First Tokyo Bar Association in Japan and the International Fiscal Association. He has an LL.B. from Tokyo University.



Dean & Heimos, LLC, conducts a tax, estate, financial planning and business law practice focusing on international transactions, personal tax and asset protection planning. The firm represents individual clients from the U.S. and abroad, as well as institutions such as offshore insurers, banks and trust companies. Located in Denver, Colorado, the firm recently opened a representative office in Geneva, Switzerland.

The firm can be contacted in the first instance at admin@deanlaw.net or (USA) (1)-303-831-8359.

Peter M. Cohen is the International Marketing Director for the Trident Trust Group, a leading provider of international corporate, fiduciary and mutual fund services. Mr. Cohen is a graduate of Rhodes University, the University of Stellenbosch and the University of London.
He is a member of the American Bar Association and various other international professional bodies.
He is a frequent lecturer and writer on international tax and administration topics.
Information on the Trident Trust Group can be accessed from their website: www.tridenttrust.com. Mr. Cohen can be contacted at (USA) 404-233-5275 or by email pcohen@tridenttrust.com.

Bruce Zagaris is a partner with the law firm of Berliner, Corcoran & Rowe, Washington, D.C. His private practice includes criminal trial and appellate work. He has served as counsel in forty-five criminal trials and appellate cases. In addition, he has handled evidence gathering and extradition cases both on the interstate and international levels and cases involving prisoner transfer applications. His criminal work has included counseling on extradition and international evidence gathering cases, testifying as an expert in international criminal cases involving money laundering and tax crimes, counseling of witnesses for grand jury investigations, prisoner rights, representation of parolees, probation revocation matters, and early release of prisoners on emergency medical problems. His private practice has also included monitoring international tax and enforcement developments in the U.S. and the Caribbean for foreign governments and corporate clients. Since 1985, he has edited the International Enforcement Law Reporter, a monthly publication which discusses developments in international criminal and related enforcement law matters. His international tax practice has included counseling twelve governments on developing international financial sector work and tax treaty strategy and negotiations. The practice has involved structuring transactions and tax compliance. His bar activities include: chair, Committee on International Tax, Section of International Law & Practice, American Bar Association, 1989-92; Chair, Committee on International Criminal Law, Criminal Justice Section, American Bar Association, 1989-93; member, Executive Committee and Executive Council, American Society of International Law, 1991-93; co-chair, Committee on Public International and Criminal Law, D.C. Bar Assoc.; and President, Washington Foreign Law Society, 1990-91. He has been an adjunct professor of law at the Washington College of Law, American University, Fordham Univ. School of Law in New York, and John Marshall College of Law in Chicago. He has authored and edited several books and hundreds of articles on international law.

Gerald R. Nowotny is a Vice President and is the Director of Advance Product Development for Marsh Financial Services. Prior to joining Marsh he was a Second Vice President in the Large Corporate Markets ("LCM") Division of Mass Mutual, and was responsible for private placement life insurance sales in the domestic and offshore high net worth markets. Prior to joining Mass Mutual-LCM, Gerry was a manager in Deloitte & Touche's National Insurance Consulting operation. Gerry had ten years of experience with several life insurance companies prior to joining Deloitte.
He is a graduate of the United Sates Military Academy at West Point, New York. He received his Juris Doctor and LL.M in estate planning from the University of Miami. He is a member of the Florida Bar. He is a Chartered Life Underwriter (CLU), and Chartered Financial Consultant (ChFC). Gerry is married and has three daughters. He speaks Spanish and Portuguese. He has published numerous articles regarding private placement life insurance and life insurance planning techniques in various legal and tax publications.

Hywel Jones was born in North Wales, Hywel was brought up and educated in the UK and the Channel Islands.
He has over 25 years experience in financial services with National Westminster Bank PLC, Jamaica Institute of Bankers, Bahamas Institute of Bankers and Canadian Imperial Bank of Commerce.
Hywel established Britannia in 1996 to provide sophisticated tax and estate planning structures for high net worth persons internationally using a variety of insurance products including annuities, life insurance and captive insurance. Britannia now has a highly qualified and experienced team of financial services professionals and has established itself as the most flexible and innovative provider of compliant, tax efficient products suitable for the new offshore regulatory environment.
An ACIB and FSD holder of the Chartered Institute of Bankers, London, Hywel is well known internationally as a writer and speaker on a range of subjects relating to banking, finance, and taxation.
He has been Bahamas Editor for Tax Notes International and Offshore Canada magazines and is a former director of both The Bankers Association of The Bahamas and The Bahamas Institute of Bankers.

David Lines is a Partner and member of the Insurance Team within the firm's Corporate Commercial Department. Mr. Lines practices corporate and insurance law specialising in corporate finance, corporate structuring and general insurance regulatory matters. David has advised on a wide variety of matters for a client base that is dominated by fortune 500 companies.
Mr. Lines trained with City of London law firm DJ Freeman and was admitted to the Law Society of England and Wales in November 1995. Upon qualification he joined the Insurance and Shipping Department of DJ Freeman where he ultimately specialised in insurance related corporate work. In particular, Mr. Lines was actively involved in the formation, purchase and listing of numerous Lloyd's corporate capital vehicles. In 1997 he returned to Bermuda and joined Appleby Spurling & Kempe.
Mr. Lines obtained a Bachelor of Science in Politics and International Relations from Clark University, Worcester, Massachusetts in 1988 and was awarded the Nicole Scholarship. He then read law at the Faculty of Laws, University College, London University graduating in 1992 with a Bachelors of Law (Hons).
Mr. Lines was a member of the AS&K team that co-authored Bermuda's electronic commence legislation, the Electronic Transactions Act 1999 and speaks and writes frequently on Insurance and e-commerce topics. Recently, Mr. Lines was named in Chambers Global "The World's Leading Lawyers."

Timothy H. Law, J.D., is a Senior Vice President in the Wealth Management division of Scottish Annuity & Life International Insurance Company (Bermuda) Ltd. He is a frequent speaker on the subject of private placement life insurance, and is actively involved in the structuring of transactions for Scottish and its clients. Prior to joining Scottish, Mr. Law practiced law, focusing on estate planning, with firms in Georgia and Texas, and served as general counsel to an insurance-based planning firm. Mr. Law can be contacted at tim.law@scottishannuity.com.

Nigel Bowrey has over 35 years experience in the life industry, occupying senior positions in UK and offshore companies. He is currently an independent consultant holding directorships on various Boards, including that of an Isle of Man insurance company. Most recently he was an executive director of Isle of Man Assurance Ltd., and previous to that, the Appointed Underwriter of Alder Life Syndicate at Lloyd's, director of Oxford Agencies, Chairman of the Lloyd's Life sub-Committee and a founding director of Lutine Assurance Services. Other experience includes 15 years in life reassurance at World-Wide Re, with responsibility for developing new business and underwriting operations.
e-mail:Ballacallin@hotmail.com Tel: +44 (0) 1624 822978.

Hugh McCormick is a partner in the New York office of LeBoeuf, Lamb, Greene & MacRae L.L.P. He advises U.S. and foreign insurance and reinsurance companies on tax, regulatory and corporate matters arising in connection with mergers and acquisitions, demutualizations, reinsurance transactions and insurance products. He is an officer and director of the Insurance Tax Conference, Inc., and is a member of the Board of Advisors and Contributors of the Journal of Taxation of Investments. Mr. McCormick received his B.A. from the University of Michigan (1968), his J.D. from Rutgers University School of Law, Newark (1977), and an LL.M. (Taxation) from Georgetown University (1980).