Insurance Tax Structuring, AVP

KKR is a leading global investment firm that offers alternative asset management as well as capital markets and insurance solutions. KKR aims to generate attractive investment returns by following a patient and disciplined investment approach, employing world-class people, and supporting growth in its portfolio companies and communities. KKR sponsors investment funds that invest in private equity, credit and real assets and has strategic partners that manage hedge funds. KKR’s insurance subsidiaries offer retirement, life and reinsurance products under the management of Global Atlantic Financial Group. References to KKR’s investments may include the activities of its sponsored funds and insurance subsidiaries.

The role will join the KKR Global Tax team, a world-class team of tax professionals dedicated to supporting KKR’s global investment activities. Led by the Global Head of Tax based out of New York, the team encompasses experts in various areas of taxation, including transaction structuring, compliance, and strategic planning. With a global presence and a focus on collaboration, KKR Global Tax plays a pivotal role in guiding the firm’s tax strategy and ensuring compliance with tax regulations across jurisdictions. The team fosters a culture of innovation, excellence, and continuous learning, providing opportunities for professional growth and development. As part of KKR Global Tax, the Insurance Tax Structuring role will have the opportunity to work alongside industry-leading professionals and contribute to the success of one of the world’s premier investment firms.

KKR is seeking a skilled and experienced tax professional to join its tax team in Boston, with a focus on insurance tax matters for Global Atlantic and KKR’s sponsored insurance vehicles.  Reporting to the Head of Insurance Tax Structuring, this role will serve as a key technical resource for investment structuring, tax planning and ongoing tax support for KKR’s insurance platform, Global Atlantic.  This position requires deep expertise in insurance taxation, investment structuring and international tax.

The scope of the role is broad and dynamic, requiring strong technical knowledge of insurance and reinsurance tax rules, excellent judgement in evaluating transaction structures, and the ability to collaborate effectively with internal stakeholders and external advisors. 

Investment Structuring & Transaction Support

• →Lead tax structuring analysis for insurance company investments across asset classes, ensuring structures are optimized for the insurance company investors
• →Advise on U.S. cross-border tax considerations, including withholding tax optimization, tax treaties, and foreign tax credit strategies and provide clear recommendations to investment deal teams
• →Partner with Deal Teams, Legal, Finance, and external advisors to structure new investments and resolve complex tax issues
• →Coordinate and oversee entity tax setup processes with external advisors
• →Support due diligence and post-acquisition integration for insurance platform investments

Sponsored Vehicle Planning & Structuring

• →Provide comprehensive tax planning and structuring support for KKR's sponsored insurance vehicles
• →Lead the design and implementation of new sponsored vehicle structures, including evaluation of domicile selection, entity classification elections (e.g., Section 953(d)), and investor considerations
• →Manage ongoing tax planning and governance for existing sponsored vehicles, including monitoring for Permanent Establishment risk and BEAT risk and other US tax risks
• →Lead tax analysis around exit options and restructurings
• →Coordinate with external counsel and advisors on complex structuring matters, including rated feeder structures and other strategic initiatives

Reinsurance

• →Advise on tax implications of reinsurance transactions and insurance structuring matters

Operating Guidelines & Risk Management

• →Develop and maintain operating guidelines to manage tax risks, including permanent establishment exposure and BEAT considerations
• →Monitor insurance operations and investments to ensure compliance with operating guidelines, partner with legal and compliance team to provide advice to the business as needed
• →Coordinate periodic employee certifications and training, board training, and other governance activities related to operating guidelines compliance

Strategic Projects & Stakeholder Management

• →Support broader strategic initiatives for the insurance platform as required
• →Stay current on legislative and regulatory developments affecting insurance taxation and communicate impacts to stakeholders

• CPA, JD, LLM in Taxation or equivalent professional credential required.
• Minimum of 7 years of relevant tax experience in a law firm, Big 4 accounting firm, insurance company, asset manager or financial services organization role, with strong experience in insurance/reinsurance, investment structuring and international tax.
• Strong analytical skills and attention to detail, with the ability to assess complex tax issues and propose practical commercially grounded solutions.
• Excellent communication and interpersonal skills, with the ability to effectively collaborate across diverse teams and stakeholders and exercise sound judgement.
• Proven ability to manage multiple priorities in a fast-paced environment and meet tight deadlines.

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