Description: On May 24, 2005, the Treasury Department and Internal Revenue Service published a notice of proposed rulemaking the “Notice” proposing regulations under Internal Revenue Code §7702, the federal tax definition of a “life insurance contract.” Discussion of determining 'attained age' for joint or multiple life policies.

Description: Taxing Times -- Volume 11, Issue 2, June 2015

Description: This article discusses the implications of a principle-based reserve PBR system with respect to federal income taxation of life insurance companies, particularly with respect to tax reserves and their deductibility for tax purposes. The article discusses potential problems with existing tax rules for reserve deduction, what courses of action the IRS could take, and suggestions for design features of a PBR approach that would make it more consistent with current tax rules. Life insurance product tax implications are also discussed.

Description: The Internal Revenue Service “the Service” or “IRS” recently released Technical Advice Memorandum 200939019 “the TAM”. The TAM initially caused a stir among some in the insurance tax industry because it disallows a tax deduction that was permitted on the NAIC Annual Statement hereinafter “NAIC statement”. Specifically, the TAM states that unpaid loss adjustment expenses “LAE” for retiree medical benefits may only be deducted in the tax year in which the benefits are included in income by the employee who earned the benefits, despite the fact the amounts were properly included on the NAIC statement and regardless of deductibility of the unpaid LAE under the Internal Revenue Code “the Code”. This article discusses the memorandum.

Description: Illustrative impacts on new business profitability of the 2017 Tax Cuts and Jobs Act for a variety of different life and annuity product types

Description: This article discusses the ruling on the new BOLI arrangement and addresses three aspects of the tax treatment of the arrangement: (1) the LLC’s taxation as a partnership as opposed to an investment company, (2) the deductibility of interest expenses by the LLC and its members, and (3) the excludability of death benefits under the Policies, which began life as employer-owned life insurance contracts.

Description: The financial crisis of the recent past has prompted the director of the financial services industry portion of the Large and Mid-Size Business “LMSB” Division of the Internal Revenue Service “Service” to announce an increased focus during audit on the reporting by members of the financial services industry of losses attributable to bad debts or to worthless securities issued by subsidiaries.

Description: The recent Tax Technical Corrections Act of 2007, Pub. L. 110-172, signed into law on Dec. 29, 2007, includes a provision that permits a taxpayer to select positions in a straddle and thereby avoid surprise applications of the straddle rules by the IRS on audit.

Description: T3: TAXING TIMES TIDBITS

Description: The Impact of Tax Reform on Federal LTCI Deductibility for Business Owners.