LLOYD'S OF LONDON

Lloyd's of London, the venerable 300 year old British insurance institution and market place has had many changes in the last decade. The principal one being the ability for investors to underwrite insurance premium income at Lloyd's with limited versus unlimited liability.

As a result of this change many American investors at Lloyd's who had previously underwriten with unlimited personal liability have changed their underwriting to a corporate form. This has resulted in a whole new set of tax issues dealing with the proper use of U.S. and U.K. tax losses, the proper capitalization of a Lloyd's insurance company and the taxation of the individual shareholders.

Mr. Lehman is expert in this rather esoteric area of the tax law as a result of his personal history of 10 years of underwriting at Lloyd's, his representation over the years of American Names at Lloyd's and the work that he has done for several Lloyd's market entities.