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Mergers & Acquisitions: Tax Liability

  • Enables insureds to reduce or eliminate a contingent tax exposure arising from tax treatment of a transaction, investment, or other tax position where the underlying legal conclusions may be subject to future challenge by the IRS or state or foreign tax authorities

  • Up to $50M capacity for any single risk

  • Coverage available for risks on a 100%, shared, layered, or excess basis from AIG’s non-admitted carriers only

  • Written advice or guidance from legal or other tax advisers obtained by the client is preferred, but not required

  • Transactions that demonstrate a clear business purpose other than to achieve a particular tax result are preferred; whether the jurisdiction has GAAR (General Anti-Avoidance Rules) in place will be taken into consideration

  • Prefer to cover risks in jurisdictions that are politically stable, have a developed legal system, and a tax authority or tribunal with a recognized, accepted route of appeal and a reputation for competence, probity, sophistication, and fairness

  • Federal, state, local, or foreign taxes considered (policy period tracks applicable statutes of limitations)

  • Expenses of legal or other tax advisors incurred in resolving disputes with the IRS and/or other taxing authorities in respect of the covered tax liability

  • Gross-up of taxes payable with respect to insurance proceeds in the event of a loss and insurance recovery

  • Interest and insurable non-criminal fines or penalties related to a covered tax liability


Dedicated and experienced claims team specialized in disputes surrounding complex transactions and in processing customer claims in an expedient manner with proven claims paying ability.

Underwriting Expertise:

Underwriting and industry expertise to craft the tailored programs required for each structured transaction.


Committed to delivering world-class multinational expertise, solutions, and service to clients in a globally consistent and seamless fashion through one of the largest global networks in the industry, spanning 215+ countries and jurisdictions.