Description: The article provides a summary of the 2017 Tax CUts and Jobs Act provisions that are most important to life insurance companies.

Description: The article deals with the critique of a technical advice memorandum issued by the IRS. It basically states the author's opinion that, although the conclusion was correct, the reasoning given was inappropriate.

Description: An extensive look at Actuarial Guideline 38, "The Application of the Valuation of Life Insurance Policies Model Regulation."

Description: The article reviews the results of a survey conducted by the taxation section to review the responses from its members.

Description: A detailed discussion on Private Letter Ruling 20123009 which states that owners of life insurance contracts in some circumstances want to decrease their death benefits and that the decreases contemplated are not ones resulting from application of a formula or other provision set forth in the contracts.

Description: The column summarizes tax and retirement matters that ACLI and its member companies have been actively addressing. These include IRS 2015-2016 priority guidance items, the Department of Labor proposed fiduciary rule, proposed IRS hedge fund reinsurance rules, and new IRS notional principal contract rules.

Description: Update on accounting and capital/RBC issues subsequent to tax reform.

Description: This article is an introduction to the principles of taxation of U.S. owned foreign insurance operations, such as controlled foreign corporations.

Description: Primer on the federal income taxation of nonqualified annuities

Description: I.R.C. § 4371 imposes an excise tax on policies issued by foreign insurers or reinsurers covering U.S. risks. The application of the tax to funds withheld reinsurance can raise difficult questions. The IRS’s position is that an accrual concept applies, although that position is questionable. Taxpayers that instead determine the excise tax by looking only to actual payments made by the ceding company to the reinsurer or to the net amount of the ceded premiums after adjusting for the allowance paid by the reinsurer have a variety of arguments to support their position. The language of the premium excise tax, the regulations thereunder, the legislative history of the provision, and the very nature of an excise tax all support the position that the tax applies only when there is an actual payment. Other Code provisions that use similar language as well as the Supreme Court also support this view.