Tax Liability Insurance

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In addition to W&I insurance policies VTS offers tax liability policies on a standalone basis.

Tax liability insurance protects the insured when the tax authority disagrees with a tax position taken by the insured. The policy covers financial loss where the tax authority deems the taxpayer to have a greater tax liability than claimed by it. Tax liability addresses a specific circumstance rather than providing general coverage as per our W&I insurance policies.

There are certain tax liabilities and transactions that fit with the use of tax liability insurance and which VTS would consider which include:

  • maintenance of operating losses and other tax attributes following a transaction;
  • transfer pricing;
  • tax treatment of reorganizations and recapitalizations;
  • capitalisation and debt versus equity analysis;
  • capital gain versus income treatment;
  • deductibility of expenses and capitalisation of expenses;
  • compensation and distributions; and
  • imposition of withholding taxes.

VTS requires tax risks to have an associated tax opinion and would not insure tax liability risks:

  • that do not have the required standard of tax opinion;
  • where there is an indefensible tax position such as caused by a lack of information;
  • relating to penalties arising from organisational errors such as late filing;
  • relating to tax avoidance or evasion; and
  • relating to commercially available tax schemes.

Volante Transaction Services SECTEUR

L'Équipe Volante Transaction Services

Martin Larkman

Global Head

Volante Transaction Services

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Martin Larkman

Global Head

Volante Transaction Services

Martin is the Global Head of Volante Transaction Services and leads the VTS team across all regions. He has a wealth of insurance, legal and commercial professional experience. Martin is a recognised transaction liability insurance sector expert with substantial M&A insurance experience having undertaken transactions across the globe and having created and led M&A underwriting teams for both boutique and global insurance institutions. Martin brings significant commercial experience to the role of Global Head having been an executive director and sat on the board of companies across North America, Europe, UK and Asia Pacific. Martin is an England and Wales law qualified solicitor who has practised law in Europe and Asia Pacific across both international and domestic markets. As a lawyer, Martin specialised in corporate M&A law and focused on international transactional private equity work. Martin’s prior experience encompasses roles working with IAG, AIG and Allen & Overy (amongst others) across 100s of transactions in a variety of jurisdictions.

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Christopher Opisso

Co-Managing Director, North America

Volante Transaction Services

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Christopher Opisso

Co-Managing Director, North America

Volante Transaction Services

Chris is a Managing Director of VTS – North America and is based in New York City where he focuses on the underwriting of transactional liability risks throughout North America. Chris is an experienced M&A professional who has worked on a wide variety of transactions as both an underwriter and a corporate lawyer. Prior to joining Volante, Chris was Managing Director at BlueChip Underwriting Services, where he underwrote representation and warranty and contingent liability insurance policies for over five years. Chris began his legal career as a corporate and finance attorney at Latham & Watkins LLP in New York.

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Jason Tomitz

Co-Managing Director, North America

Volante Transaction Services

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Jason Tomitz

Co-Managing Director, North America

Volante Transaction Services

Jason is a Managing Director of VTS- North America and is based in New York City, where he focuses on the underwriting of transactional liability risks throughout North America. Jason has 12 years of M&A experience, including almost 4 years at BlueChip Underwriting Services where Jason worked as Managing Director and Head of Tax and underwrote both tax and RWI policies. Prior to joining BlueChip, Jason was a tax attorney for more than eight years and practiced law at Kramer Levin Naftalis & Frankel, Farrell Fritz, PC and Olshan Frome Wolosky LLP. Jason graduated summa cum laude from the Maurice A. Deane School of Law at Hofstra University in 2011

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Jonathan Sprintz

Co-Managing Director, North America

Volante Transaction Services

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Jonathan Sprintz

Co-Managing Director, North America

Volante Transaction Services

Jon is a Managing Director of VTS – North America and is based in New York City, where he focuses on the underwriting of transactional liability risks throughout North America. Jon has 9 years of M&A experience, including 5 years at BlueChip Underwriting Services, where Jon worked as a Managing Director and underwrote risks across a variety of industries, with a focus on healthcare transactions. Prior to joining BlueChip, Jon was a corporate and M&A attorney for 4 years and practiced law at Winston & Strawn LLP and Henry Schein, Inc.

 

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Shaun Reynolds

Regional Managing Director - ANZ

Volante Transaction Services

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Shaun Reynolds

Regional Managing Director - ANZ

Volante Transaction Services

Shaun is the Regional Managing Director for Australia and New Zealand, based in Sydney. In addition to growing the ANZ business, Shaun will work on transactional liability risks with the VTS APAC team. Shaun has over 16 years’ M&A experience and for the last six and a half years Shaun has worked as a senior underwriter for AIG’s Asia Pacific M&A insurance team where he underwrote risks across ANZ and Asia. Prior to that Shaun worked in top-tier law firms in Sydney and London (including Herbert Smith Freehills) and as in-house counsel with MNCs, including GlaxoSmithKline and Booz & Co.

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Daniel Thieviasingham

Deputy Managing Director Volante Transaction Services - APAC

Volante Transaction Services

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Daniel Thieviasingham

Deputy Managing Director Volante Transaction Services - APAC

Volante Transaction Services

Daniel is a Deputy Managing Director in Singapore, working as part of the VTS APAC team on transactional liability risks. He brings over 10 years’ M&A experience and for the last six and a half years Daniel has worked in a number of roles within the transactional liability space, including most recently as a senior underwriter for Berkshire Hathaway Speciality Insurance’s Asia Middle East M&A insurance team. Prior to that Daniel spent two years in London as a Transactional Risk broker for Lockton, placing W&I and tax insurance policies and before that was a Transactional Risk underwriter in Ironshore’s (now Liberty GTS) Sydney office where he focused on transactions across the Asia-Pacific region.

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Krzysztof Jagiello

Country Manager, Poland

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Krzysztof Jagiello

Country Manager, Poland

Volante Transaction Services

Krzysztof is the Head of CEE and is based in Warsaw, where he focuses on the Polish transactional risk insurance market. Prior to joining Volante Global, he worked as a Polish qualified lawyer at the Polish offices of Dentons, Weil & Gotshal Manges and DWF assisting clients on both domestic and cross-border M&A transactions (including mergers, demergers, asset deals and share deals), drafting and negotiating business contracts and providing ongoing assistance in corporate and commercial matters. Krzysztof is fluent in Polish, English and German.

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Massimiliano Moschen

Head of Italy

Volante Transaction Services

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Massimiliano Moschen

Head of Italy

Volante Transaction Services

Massimiliano is the Head of Italy and is based in Milan, where he focuses on the Italian transactional risk insurance market. Prior to joining Volante Global, he worked at AIG, focusing on Warranty & Indemnity and Contingent Risk insurance policies in Italy and across South Europe. During his experience at AIG, he was also seconded to the DACH team in the Frankfurt am Main office, where he worked on risks located in Germany, Austria and Switzerland. Prior to that, Massimiliano worked as Italian qualified lawyer for Italian and international law firms in Milan, assisting clients on both domestic and cross-border M&A transactions (including mergers, demergers, asset deals and share deals), drafting and negotiating business contracts and providing ongoing assistance in corporate and commercial matters. Massimiliano is fluent in Italian, English and German.

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Marco León Tadeo

Senior Underwriter

Volante Transaction Services

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Marco León Tadeo

Senior Underwriter

Volante Transaction Services

Marco is Head of Iberia and is based in Barcelona, focused in developing Volante Global’s operations in the Iberian region. Prior to joining Volante Global, he worked in the Iberian W&I and M&A space, both as an M&A underwriter and an M&A lawyer. As a Spanish qualified lawyer, Marco has extensive knowledge of corporate M&A law, holding also an LLM in tax law. With a focus on international transactional private equity work, Marco boasts over 10 years of M&A experience. Marco is fluent in Spanish, English and Catalan, and holds intermediate Mandarin capabilities.

 

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Cristobal Silva

Underwriter, UK & Europe

Volante Transaction Services

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Cristobal Silva

Underwriter, UK & Europe

Volante Transaction Services

Cristobal is an Underwriter within the VTS UK & Europe team and is based in London. Originally a Chilean qualified lawyer, Cristobal brings over 8 years of international M&A experience to VTS. He worked at Carey, Chile’s largest and most prestigious law firm, and focused his practice in corporate and business law, financing, telecommunications and real estate matters. Prior to joining Volante Global, he completed a Master of Laws (LLM) programme at King’s College London, during which he broadened and deepened his knowledge of the UK legal market, especially in M&A, insurance, and corporate governance matters. Cristobal is fluent in English and Spanish.

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Pierre-Samuel Dahan

Underwriter

Volante Transaction Services

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Pierre-Samuel Dahan

Underwriter

Volante Transaction Services

Pierre-Samuel is a French qualified lawyer and joined Volante in 2023 as a Senior Underwriter. Prior to Volante, Pierre-Samuel worked as an M&A and Tax underwriter at Transact Risk Partners for 4 years where he developed robust and transversal underwriting skills, both in respect of M&A insurance and tax insurance products. He also gained experience in the tax departments of major law firms in Paris (such as CMS and Linklaters) where he came across various tax matters in relation to private equity operations and corporate reorganizations. He holds a master’s degree in business law as well as a master’s degree in tax law (both from Sorbonne University). In addition, he graduated with an MBA from the University of Amsterdam where he acquired specific business skills notably in corporate finance, accounting, and corporate strategy.

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