Kenneth S. Levinson

Senior Counsel

Overview

With 30+ years of tax experience, 20+ years of aviation experience, and 20+ years of insurance experience including captive insurers and risk management, Ken Levinson puts a wealth of knowledge to work for clients.

Tax

Ken advises clients on international tax issues, including:
  • Worldwide tax planning
  • Transaction structuring
  • Foreign bank account reporting
  • M&A
  • Licensing
  • International franchising
  • Expatriate tax issues
  • Audits
  • Controversy management
  • Negotiation and litigation
  • Voluntary disclosures
  • Compliance for all federal, state and foreign taxes

Ken has also served in court as a witness in international tax matters.

Insurance

Ken helps clients structure insurance matters in a way that manages risk. He advises on:
  • Strategic design, tax structuring and implementation of captive insurance companies and RRGs
  • Insurance programs
  • Resolving tax issues involved in captive insurance arrangements
  • Analysis of domiciles
  • Surplus lines taxes
  • Negotiating and purchasing insurance placements and policies
  • Loss prevention
  • Managing and negotiating claims
  • Designing and assessing broker RFPs.

Past Tax Experience

Prior to joining Faegre Baker Daniels, Ken was a managing director of the Midwest region in the captive and warranty practice of KPMG. Earlier in his career, Ken held vice president positions with Northwest Airlines (with executive management responsibilities for the corporate tax and risk management departments and as senior finance officer in the cargo division) and Marriott Corporation (with responsibilities for international finance, international tax, and tax administration and controversies).
 
He also served as assistant branch chief in the Internal Revenue Service Office of Chief Counsel, Washington D.C. In this role, Ken was assigned to the Department of Justice as technical advisor to assist in the “Project Haven” criminal tax investigation involving offshore tax havens

Faculty Positions

  • Georgetown University Law Center — Originated and taught two-semester international tax course for LL.M. graduate tax program
  • University of Minnesota Law School — International tax course instructor

Credentials

Bar Admissions

District of Columbia
Minnesota
Virginia

Education

Georgetown University
LL.M. Tax, with honors (1978)

George Washington University Law School
J.D. with high honors (1975)

University of Wisconsin, Madison
B.A. with distinction (1969)

Insights & Events

Other Perspectives
  • Tax Issues in International Franchising
    Co-author, The International Journal of Franchising Law, October 2015 
  • Introduction to, and Overview of, U.S. Tax Treaties
    Co-presenter, Minnesota State Bar Association, October 2015
  • Career Choices and Development Opportunities in Tax
    University of Minnesota Law School, October 2015
  • Direct Selling Internationally: Tools for Navigating the Business and Tax Pitfalls
    Co-presenter, Direct Selling Association, 2015 Global Strategies Summit, October 2015
  • New Frontiers in International Franchising: Tax Issues for International Franchising for Dummies
    International Bar Association/International Franchise Association, 31st Annual Joint Program, 2015
  • International Tax Polar Plunge: Cold Reality of Inversions, FATCA and Expatriations
    Minnesota State Bar Association, 2015
  • Update on International Tax Issues and Proposals for Reform
    Minnesota Bar Association, Tax Institute, 2014
  • Employing Staff in and From Asia
    The Expatise Academy, Amsterdam, Tax Faculty, November 2014
  • International Issues
    Chapter co-author in Mergers and Acquisitions of Franchise Companies, Second Edition, American Bar Association, 2014
  • What Are "Inversions?"
    Minnesota Center for Fiscal Excellence Newsletter, July 2014
  • Key Tax Issues in International Franchise Transactions
    International Franchise Association, 47th Annual Legal Symposium, 2014
  • Placing Employees in Europe: Case Studies in Employment Benefits and Corporate Tax Challenges
    Forum for Expatriate Management, 2014
  • Update on International Tax
    Minnesota State Bar Association, 2013 Tax Institute
  • Perspectives on Taxation
    Moderator, University of Minnesota Law School Corporate Institute, 2013
  • Utilizing Captive Insurance Companies in Franchising
    Franchise & Distribution Corporate Counsel Summit, 2013
  • Captives: Procurement Taxes, Regulatory Issues and NRRA
    Captive Insurance Companies Association, International Conference, 2013

Leadership & Community

Professional Associations

  • Minnesota Center for Fiscal Excellence, 1990-present — Board President, 2004-06; Executive Committee member, 2006-present
  • National Tax Association — Board, 1999-2002
  • Tax Executives Institute, Minnesota Chapter — Board, 1998-2002
  • Air Transport Association — Tax Committee and Insurance Committee (Former Chair)
  • International Air Transport Association — Risk and Insurance Managers Panel (Former Chair)
  • American Bar Association
  • Minnesota, Virginia and District of Columbia Bar Associations
  • Carver County Sheriff's Mounted Posse — Deputy sheriff, 2002-present; Board Member, 2010; Training Committee (Chair, 2012-present)
  • Search, Rescue and Recovery Resources of Minnesota, 2008-present — Counsel to Board, 2010-present

Honors

  • The Best Lawyers in America — Tax Law, 2010-17; Litigation & Controversy - Tax, 2012-17
  • The Legal 500 — Tax, Aviation and Captive Insurance
  • Top Lawyers in the State, 2011-15
  • Who's Who in American Law
  • Who's Who International
  • Who's Who in Executives and Professionals
  • Faegre Baker Daniels — Pro Bono Honor Roll, 2015-17
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