John T. Adney
Of Counsel
John helped found Davis & Harman LLP in 1985 and was the firm's first managing partner. His insurance product taxation advisory, ruling and audit practice covers universal life insurance, variable life insurance, group-term life insurance, COLI, fixed and variable annuities, long-term care insurance, and business and compensatory uses of the products. In addition, he has conducted extensive advisory and ruling work relating to insurance company taxation.
Since 1980, John has represented insurance companies on tax matters relating to the companies and their products, including the enactment or revision of Internal Revenue Code sections 72, 101(f), 101(g), 101(j), 264, 801-818, 845, 846, 1035, 7702, 7702A, and 7702B. Prior to founding Davis & Harman, he was a partner in the insurance tax practice of Sutherland, Asbill & Brennan and served as law clerk in the Trial Division of the US Court of Claims and to Judge Marion Bennett of the Court of Claims Appellate Division.
"Life insurance companies are among the most complex institutions in the world," says John Adney. "Their tax issues present continually fascinating challenges for lawyers."
In his long legal career, John takes special pride at being present at the creation of universal life insurance and helping to resolve its basic tax treatment. During the process, he helped fashion legislation addressing life insurance and annuity taxation throughout the 1980s and 1990s.
John is a prolific writer on insurance taxation topics. He co-authored a textbook on life insurance product taxation, Life Insurance & Modified Endowments (Society of Actuaries, 2004). He is also the co-author of the Annuities Answer Book (Aspen Publishers, 4th ed. 2005) and of the chapter on taxation in Variable Annuities & Variable Life Insurance Regulation (Practising Law Institute, 2008). His byline appears on numerous articles on the taxation of insurance companies and products. Three of his articles, published in the Journal of Financial Service Professionals and its predecessor, won author awards from Journal readers. John is currently an Associate Editor of the Journal.
John has often been a speaker at programs of the Insurance Tax Conference, Society of Actuaries, National Association for Variable Annuities, and American Bar Association. He currently serves as a member of the Council of the Taxation Section of the Society of Actuaries.
He received his B.A. summa cum laude from Millikin University in 1972 and his J.D. from Yale Law School in 1975. A native of Illinois, John and his wife have commissioned over a dozen choral and orchestra musical works—including works for Wolf Trap, Reston Chorale, Reston Community Orchestra and United Christian Parish of Reston. He is Chair emeritus of his alma mater Millikin University Board of Trustees.
Prior Experience
- Partner, Sutherland, Asbill & Brennan
- Law Clerk to Judge Marion Bennett, US Court of Claims, Appellate Division
- Law Clerk, US Court of Claims, Trial Division
Professional Memberships
- American Bar Association, Section of Taxation
- Past Chair, Committee on Insurance Companies, ABA Section of Taxation
- Association of Life Insurance Counsel
- Chair emeritus, Millikin University Board of Trustees
Bar and Court Admissions
- District of Columbia
- US Supreme Court
The Willard 1455 Pennsylvania Avenue, NW
, Suite 1200
Washington, DC 20004 Tel 202-347-2230
Fax 202-393-3310
Education
- BA, summa cum laude, Millikin University, 1972
- JD, Yale Law School, 1975
Recent Publications
and Presentations
- ANNUITIES ANSWER BOOK, FIFTH EDITION
- RECENT IRS RULINGS HIGHLIGHT INVESTOR CONTROL ISSUES FOR FUND OF FUNDS ARRANGEMENTS
- IN THE BEGINNING: A COLUMN DEVOTED TO TAX BASICS: PREMIUMS PAID, INVESTMENT IN THE CONTRACT, AND TAX BASIS – WE KNOW IT WHEN WE SEE IT, RIGHT?
- IRS Notice 2016-63—Safe Harbor Guidance for 2017 CSO
- Product Tax Implications of the Adoption of the 2017 CSO Tables
The Willard
1455 Pennsylvania Avenue, NW
Suite 1200
Washington, DC 20004
Tel 202-347-2230
Fax 202-393-3310
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