RCP has recently enhanced its tax risk consulting team with the addition of a new partner, Roy Reynolds. Roy brings to RCP his experience as a practicing tax attorney. He is also an experienced underwriter, with a specialization in tax indemnity insurance. Prior to joining RCP, Roy was an underwriting manager in Chubb's department of financial institutions. Roy has strong educational credentials in law, finance and insurance. He is a registered professional liability underwriter, with a JD degree from Georgetown University Law Center and an MBA in finance and accounting from the University of Chicago.

RCP offers consulting services to mitigate tax risk at all stages of the tax assessment process. Our tax risk solutions include:

1. Transfer of tax risk through insurance.
2. Audit of compliance procedures to identify weaknesses that may lead to tax payment deficiencies and penalties.
3. Negotiation with the IRS to resolve tax issues and reduce penalties.

RCP offers cutting edge insurance solutions to mitigate tax risks and monetize tax benefits. One example involves capitalizing on a tax refund to which a company is entitled. A large tax refund might take six months to one year to process. In the meantime, the company might need the cash immediately, to enhance its working capital or liquidity. Insuring the refund enables the company to obtain a bridge loan at a lower cost, using the insured refund as collateral.

Another new and innovative product is Fin 48 insurance. Fin 48 requires companies to estimate and disclose their contingent tax liabilities. This valuable insurance product:

1. Provides cash when needed if adverse tax assessments exhaust the reserves (or the retention);
2. Adds credibility to the FIN 48 analysis, because an insurer has reviewed and "guaranteed" the recognition of tax benefits; and
3. Adds financial support to the position, if taken, that any change in reserves would be immaterial.

The addition of Roy Reynolds to the RCP team provides additional expertise in insurance, law and finance to customize such solutions for our clients. For a tax risk assessment, assistance with compliance matters such as penalty prevention or reduction, or mitigation of your tax risk through insurance, please contact Roy at (212) 496-7478.