Description: The PPACA imposed a market share-based health insurance provider fee, known as the "Section 9010 Fee", "Health Insurer Fee", or simply the "HIF", on each “covered entity” with net premiums written in excess of $25 million that is engaged in the business of providing health insurance coverage for U.S. health risks. This article provides background information to help unpack the language behind the Section 9010 Fee and highlights a few areas of special interest including merger and acquisition-related issues, application of the Section 9010 fee to expatriate plans, and considerations regarding fee administration.

Description: Provides a summary of recent proposed regulations for the health insurer fee, section 9010 of the Affordable Care Act (ACA).

Description: Over the past few years, the Internal Revenue Service has issued two private letter rulings waiving the failure of certain fixed-premium universal life insurance FPUL contracts to satisfy the guideline premium test GPT under section 7702 of the Internal Revenue Code [see PLR 200328027 Apr. 10, 2003 and PLR 200230037 Apr. 30, 2002].

Description: Prevailing Standard Mortality and Morbidity Tables May Be Adjustable for Tax Reserves

Description: Withholding and Reporting May Not Be Required for Income on Failed Life Insurance Contracts

Description: The Chairperson addresses the readers.

Description: Description of general tax consequences of purchasing an insurance company, either through buying the assets or buying the stock.

Description: Company Tax Issues

Description: Addresses the question: “If it is accepted that reserves should be pre-tax, why should required capital be post-tax?”

Description: Company Tax Issues