Description: We frequently are asked what to do when a company has reported aggregate estimates of tax reserves on the tax return, instead of tax reserves computed precisely according to the requirements of the Internal Revenue Code, and the IRS has challenged the reserve deduction. Other sections of this article also cover IRS rulings on the treatment and valuation of an insurance company stock purchased as an asset acquisition and COLI life insurance.

Description: A discussion of the American Financial case in detail. Also includes background on what the statute requires and the Internal Revenue Service (IRS)’s ruling and litigating positions.

Description: Many life insurance companies that issue participating policies follow business practices that they argue allow them a deduction for tax purposes for policyholder dividends in the year prior to actual payment. This article discusses several recent developments related to policyholder dividend accruals, including Revenue Ruling 2011-29 and the New York Life and MassMutual cases, and highlights the four arguments commonly made by the IRS in challenging companies' claimed tax treatment of such dividends.

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

Description: Tidbits include discussions about: Policy loans in excess of cost basis, treatment of loss adjustment expenses, LAE, for life insurance companies, and separate account investments in group trusts.

Description: Discusses the problem with the computation of tax reserves for VA contracts with Guaranteed Living Benefit riders that were issued prior to December 31, 2009.

Description: A discussion of the issues to be considered for computing tax reserves relating to guaranteed renewable and noncancellable health insurance and how these concerns are sometimes overlooked.

Description: On March 25, 2010, the Treasury and IRS issued Notice 2010-29. The new Notice follows-up Notice 2008-18, in which the Treasury Department Treasury and the Internal Revenue Service IRS identified concerns regarding proposed Actuarial Guideline VACARVM and suggested approaches that might be taken to address those issues. Actuarial Guideline VACARVM was effective, as AG43, beginning on Dec. 31, 2009. This discussion is the fourth in a continuing series of interdisciplinary dialogues in TAXING TIMES on selected tax issues related to proposals regarding principle-based reserves.

Description: Comparison of statutory and tax accounting rules in treatment of non-performing assets.

Description: Reserves for Annuity Contracts that Flunk Section 72(s) Can be Deductible