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Ken is an experienced and recognized transactional tax lawyer who advises clients on a wide range of international tax, structuring and business issues. He also advises clients on structuring captive insurance companies, their tax impacts and audit issues.
Ken focuses on worldwide tax planning, transaction structuring and a number of tax issues related to mergers & acquisitions, IP licensing, employee relocation, and international franchising. He has extensive experience dealing with compliance for all federal, state and foreign taxes, expatriate tax issues, audits, appeals proceedings, controversy management, negotiation and litigation, foreign bank account reporting (FBARs) and voluntary disclosures.
Ken also helps clients with insurance matters including strategic design, tax structuring and implementation of captive insurance companies, including evaluation of micro-captives and nonadmitted insurance obligations, advising on insurance programs, analysis of domiciles, loss prevention, managing and negotiating claims, and advising on broker RFPs.
Prior to joining Fredrikson, Ken was a partner with another large Minneapolis law firm where he led the international tax and captive insurance company taxation practices. He also worked with KPMG as the managing director of the Midwest region in the captive and warranty practice. Prior to these roles, Ken held executive positions with Northwest Airlines, where he was responsible for the Tax and Insurance Departments and served as CFO and chief strategy officer of the Cargo Division, and with Marriott Corporation, where he was responsible for international project finance and for federal and international tax matters, audits/appeals, and federal tax legislative matters. Ken also served as Assistant Branch Chief in the Office of Chief Counsel at the Internal Revenue Service, Washington, D.C., and was a special advisor to the U.S. Department of Justice on the Project Haven Federal grand jury investigation.
Ken previously taught the graduate level international tax course in the LL.M. (Tax) program at Georgetown University Law Center for nine years, and now teaches the international tax course at the University of Minnesota Law School. He has been an expert witness in Federal court on international tax matters and is a frequent speaker and author on various international tax matters.
December 3, 2021
By Kenneth S. Levinson and Masha M. Yevzelman
If you are into Foreign Bank Account Reports (FBARs), your concern about penalties for failing to comply with those FinCEN 114 reporting rules just took an exciting, and perhaps fearsome, turn.
September 16, 2021
By Ken Levinson
This week, we turn to international transactions that involve licenses or the provision or performance of e-commerce services.
September 9, 2021
By Ken Levinson
The transfer or use of intangibles generally is a complicated area of taxation, and one that continues to evolve.
July 15, 2021
Last week, we reviewed the basics about captive insurance companies, nonadmitted insurance and the essence of the federal legislation known as the NRRA. This week, we examine what the states did to implement NRRA and how that affected, or may affect, insurance premiums paid to out-of-state captives.
July 8, 2021
We are seeing increased focus by state tax departments on nonadmitted insurance premium reporting, tax payments owed and auditing of captive insurance companies. This article is Part I of our primer on the application of the nonadmitted premium tax rules to purchases of insurance from out-of-state captives.
February 16, 2021
By Kenneth S. Levinson and William M. Howieson
Minnesotans whose “home state” is here and who purchase “nonadmitted insurance” directly from insurers not licensed to sell insurance in Minnesota are required to file Form IG255 annually with the Department of Revenue.
March 21, 2020
By Kenneth S. Levinson, Masha M. Yevzelman, David B. Tibbals and Karen Sandler Steinert
COVID-19 has had innumerable impacts on our daily lives. In response, the IRS and certain local states have provided guidance for taxpayers whose federal income tax returns are due on April 15.
