Susan E. Seabrook is a recognized insurance industry lawyer “recommended for all insurance and reinsurance controversy” by Legal 500. Susan’s advice to clients integrates practical and strategic considerations with technical tax analysis, and is informed by her experience as a litigator for the Internal Revenue Service and her subsequent role as the IRS National Office’s insurance industry tax counsel. She is particularly adept at best practices to proactively manage IRS examinations and strategic approaches to IRS settlements.
In addition to insurance companies, Susan’s diverse client base includes multinational corporations, financial institutions, private equity, healthcare companies, and high net worth individuals. She advises clients in connection with complex transactions involving insurance companies, products, and structures, and represents clients in all phases of discovery and at trial. Susan focuses on big picture strategic issues such as choice of forum, factual development techniques, expert witnesses, effective use of Freedom of Information Act (FOIA) requests, and discovery (particularly e-discovery techniques). She successfully resolves matters involving complex technical and procedural issues, high-profile IRS initiatives, and the IRS’s invocation of judicial doctrines and anti-abuse provisions, frequently at an early stage of administrative development—an essential element of any effective tax risk mitigation strategy.
During her tenure as a senior trial attorney for the IRS and an attorney advisor in the National Office of Chief Counsel (Financial Institutions and Products), Susan received the IRS’s Special Act Award three times, including for significant issue litigation (reinsurance). She also received two Performance Awards for superior performance. Susan served as acting assistant district counsel and was designated a special assistant US attorney by the United States Attorney General.
Gonzaga University School of Law, 1985, Juris Doctor
University of Colorado at Boulder, 1982, Bachelor of Arts
University of Denver College of Law, 1990, Master of Laws
District of Columbia
Awards and Affiliations
Member, Board of Directors, Insurance Tax Conference
Former Chair, Insurance Companies Committee, American Bar Association, Tax Section
Barrister, J. Edgar Murdock (Tax Court), American Inns of Court
Adjunct Professor, University of Baltimore School of Law, Masters of Taxation Program (2003)