Corporate Counsel - Brighthouse Financial

At MetLife, we're leading the global transformation of an industry we've long defined.  United in purpose, diverse in perspective, we're dedicated to making a difference in the lives of our customers.
In January 2016, MetLife announced a plan to pursue the separation of a substantial portion of its U.S. Retail segment. Once separated, the new business will be called Brighthouse Financial.
Brighthouse Financial will serve customers the way they want, need and deserve. It will focus on eliminating the complexity, confusion and cost that can get in the way of many Americans who are seeking financial security. We will bring products to the market that add value to our customers' lives, and will be guided by a common set of values that focus on the customer and drive accountability.
Brighthouse Financial is seeking high-performing team members who are passionate about the company's mission.  We are laser-focused on adding value to our customers and minimizing complexity in every decision and action. We are building high performing teams who set the bar high and hold each other accountable.
Job Location
United States : North Carolina : Charlotte
Alternate Job Location
Not Applicable : Not Applicable
Summary of Responsibilities
The Product Tax Senior Counsel will be responsible for advising the enterprise with respect to the impact of tax law as it relates to insurance products. The role requires this position to research, review, analyze and apply tax law to relevant enterprise products and operations. The position is also responsible for coordinating and liaising with the tax reporting and compliance teams and front office staff.  The position will involve review of tax issues related to new and actively marketed product and assist with MEC issues as well as Internal Revenue Code (IRC) Sections 101, 7702, 7702A, and 79 compliance. Products covered by this team include variable life, universal life, term life, whole life, and individual disability income products.  This position will report to the Product Tax Director.
Principal Responsibilities 
  • Research and provide tax planning support for Brighthouse Financial's insurance products, including variable life, universal life, term life, whole life, and individual disability products
  • Research and provide tax planning support for Brighthouse Financial's annuity products, including variable, fixed, and indexed annuities
  • Provide tax guidance around the design of new life products (e.g., life insurance, annuities, long-term care) regarding qualification with the IRC requirements
  • Provide tax guidance regarding both the interpretation of IRC requirements and the procedures in place (administrative or otherwise) for monitoring compliance, including:
  • Provide advice on 1035 exchanges, as well as advice on investor control and the diversification requirements of Section 817
  • Life insurance; advice on compliance with sections 79, 101, 7702, 7702A
  • Advice on the design and administration of qualified and non-qualified annuity products under IRC Sections 72, 408 and 408A
  • Advice on correcting excess contributions, contract reinstatements and other annuity administration issues
  • Qualified long-term care (riders to life policies): Section 7702B
  • Provide tax guidance regarding both the interpretation of IRC requirements and the procedures in place (administrative or otherwise) for the:
  • Identification of taxable payments to policyholders and beneficiaries
  • Determination of amounts includible in income for non-qualified life insurance and annuity contracts under Section 72 (e.g., cost basis determination)
  • Administration of required minimum distributions
  • Issuance of proper information returns (e.g., Forms 1099, Form 5498, 704 and state notice and consent rules)
  • Perform tax review of all marketing material for Brighthouse products (both life and annuity) whether branded or white label.  Review for tax compliance and consistency with administrative practices.  Advance market conversations with wholesalers as/when needed
  • Serve as a liaison to various functional areas to provide tax advice and work with the functional areas to mitigate product / policyholder tax compliance risk, including:
  • Actuarial (e.g., new product development: section 7702 qualification for life insurance, section 72 qualification for non-qualified annuities); MEC testing, CVAT; GPT and determining when there has been a material change and the consequences.
  • New business issuance (e.g., section 1035 compliance, riders, indemnification agreements between carriers)
  • IT (e.g., administrative system compliance, illustration systems)
  • Policy holder services (e.g., day to day processing of transactions to insure procedures are following and qualification requirements are met)
  • Payments and distribution (e.g., proper identification of payments and determination of amounts includible in income)
  • Tax reporting (e.g., issuance of proper information returns to owners residing in both US and non-US jurisdictions)
  • Support review of issues related to potential product tax noncompliance, policyholder remediation, determinations of potential liability, and remediation with the IRS as and when necessary
  • Support training and awareness to resources in functional areas, e.g., ad-hoc training, internal webinars, lunch-and-learns, etc.
  • Maintain industry awareness, assess/monitor/ track impact of new legislation and regulatory changes on company's product tax compliance, e.g., R&D, attend industry meetings
Supervisory Responsibilities
  • None Travel
  • N/A
Required Qualifications 
  • Member in good standing of the NC or NY Bar
  • Minimum 4-7 years of product tax experience in the life insurance industry or in a major law firm working with life insurance company clients
  • Broad  experience on federal and state tax issues with significant focus on life insurance tax matters
  • Experience with insurance product tax IRS letter rulings, waivers, and closing agreement processes
  • Technical experience in insurance product taxation
  • Excellent writing and oral communication skills in order to engage with management effectively
  • Ability to assist with the resolution of technical questions and uncertainties in a manner that meets Brighthouse Financial business goals and maintains a high compliance culture
  • Ability to listen and appreciate stakeholder concerns and understand business issues that are affected by tax technical matters
  • Exhibits initiative and the ability to manage multiple complex tasks towards completion
  • Candidate should be flexible and motivated, a self-starter who can succeed in a fast-paced environment
  • In order to post for this position, you need the proper work authorization to work in the country where the position is located and not require relocation assistance.
Preferred Qualifications
  • LLM in Taxation or corresponding experience in insurance product taxation strongly preferred
Required Education
  • JD from an accredited US law school
Business Category
Brighthouse Financial
Job Category
Legal Affairs
Number of Openings

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