Description: This article outlines the IRS directive published in July 2014, which provides a safe harbor treatment for variable annuity hedging gains and losses relating to VA contracts issued before Dec. 31, 2009.

Description: This article begins with an overview of how the tax treatment of partial exchanges has evolved over the last decade or so, including the concerns that led the Service to resist giving taxpayers carte blanche on such transactions.The new guidance shortens from 12 to six months the window following a partial exchange in which the transaction could be called into question, and simplifies the regime by de-linking it from the exceptions to the section 72q penalty tax.4 Finally, the guidance provides coordination with recent partial annuitization legislation and answers to other open issues. This article then summarizes Rev. Proc. 2011-38 and elaborates on why the features outlined above are important and helpful improvements over prior guidance.

Description: The rules governing the tax treatment of distributions from life insurance or annuity contracts are complex. Worse, the relevant IRC section, section 72, seems at times to be the product of a conspiracy in restraint of understanding.

Description: On July 14, 2005, the FASB issued an Exposure Draft of a proposed Interpretation, Accounting for Uncertain Tax Positions—an Interpretation of FASB Statement No. 109. If adopted, the proposed Interpretation is the most significant tax accounting guidance the FASB has issued since FASB Statement No. 109 “Accounting for Income Taxes,” FAS 109 in 1992.

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: Highlights of recent activities of the Taxation Section

Description: A description about current efforts of several Central and Southern Europen countries to improve penetration and density of insurance coverage, in the personal view of Renata De Leers. De Leers has spent many years consulting with regulators and industry leaders, and is an advocate of inclusive insurance solutions, as a way to foster economic development.

Description: The IRS believes that any segregated asset account comprised of a pool of individual securities will run afoul of the investor control doctrine. This article articulates that such a conclusion would be deeply flawed based on the administrative, congressional, and judicial precedents involving the investor control doctrine.

Description: Article discusses recent changes in the IRS LB&I Division's examination practices and approach that may affect the work-flow of company actuaries and may present opportunities to resolve tax issues for companies

Description: SOA Taxation Section membership trends and 2018 Survey Results