Linda Sciuto provides strategic planning and solutions to multinational clients, primarily insurance and energy companies, on U.S. tax and insurance law issues. Linda concentrates on tax planning, compliance and transactional matters including, the tax aspects of international and U.S. transactions involving subchapter L, life insurance products, U.S. income tax treaties, mergers and acquisitions, controlled foreign corporations, ownership changes under Code section 382 and tax attribute transfers under Code section 381, U.S. federal excise tax (FET) issues.
In a working relationship that spans more than 21 years, Linda has represented Lloyd’s of London in connection with all U.S. federal income and FET issues, including transfer of tax attributes in a consolidation, U.S. tax impact of reinsurance programs, investment in U.S. securities, determination of subpart F income and E&P, matters concerning Qualified Intermediary status, U.S. federal income tax and FET audits. Linda handles matters that impact both the members of Lloyd’s and Lloyd’s members’ and managing agents, and has an in-depth knowledge of the Lloyd’s market. She interfaces with the IRS regularly on behalf of the client and has represented Lloyd’s before the IRS and the U.S. Treasury Department in connection with the negotiation of various closing agreements.