Description: This 1978 session examines income taxation for North America. Topics covered: I. Canadian Income Tax a. What problems and deficiencies have been found in the new Canadian income tax act and regulations? b. What effect will the new tax rules have on profits, pricing and plan design? Is the overall tax burden fair? Is it fairly distributed? 2. U. S. Income Tax a. What impact will proposals for tax reform, if adopted, have on the life insurance business in the U.S.? What alternatives have been proposed by the industry? b. Are legislative changes needed in the 1959 Company Tax Act? If so, in what areas? c. What are the implications of recent Court decisions?

Description: Reviews Elmer R. Benedict's book entitled Protecting Retirement Against Inflation, which present a broad program for equitable sharing of the inflation burden. The kingpin is an income adjustment, utilizing income taxes, designed to restore the purchasing power of the retired, disabled and surviving spouses.

Description: IRS published final regulations on updated life expectancy and distribution period tables used for determining RMDs. The article intends to provide an overview on the development of the final regulations and highlight the key updates in final regulations, the transition rules to apply final regulations and some of the relevant issues not addressed in final regulations (e.g. MITT, Rev. Rul. 2002-62 and Notice 2004-15). The article also briefly discusses what financial institutions and actuaries would like to do before the regulations become effective on Jan. 1, 2022.

Description: 1994 SOA Meeting, San Antonio. This session provided an update from representatives of the IRS and the Department of the Treasury on several topics including: 1. PBGC issues. 2. Social Security issues. 3. Health care issues. 4. Title I issues. 5. Broad principles underlying some remedial amendment period issues.

Description: Notice 2004-611 is the latest in a series of administrative pronouncements from the Internal Revenue Service related to the appropriate mortality assumptions to be used in computing the definitional limitations under Internal Revenue Code Section 7702 and the seven-pay limitation under the Section 7702A modified endowment rules.

Description: This article reviews the definition of “cash surrender value” in section 7702f2A and in the regulations proposed under that provision but never finalized. The discussion then recaps the 2005 Rulings and describes the recently issued letter rulings.

Description: In this session, panel members speculate about changes to insurance company taxation, policyholder taxation and insurance product taxation in the 1980's. Both U.S. and Canadian viewpoints are shared.

Description: The Internal Revenue Code includes certain rules that apply when a taxpayer has a change in method of accounting. A special rule applies when a life insurance company changes its basis of computing reserves. The article discusses two recent court cases, Bosamia v. Commissioner and Capital One Financial Corp. v. Commissioner, that address change-in-method-of-accounting issues. The article examines whether and how the courts' conclusions in these two cases might apply to changes in basis of computing reserves to correct errors.

Description: The article summarizes the provisions of H.R. 1 that impact the tax qualification of life insurance contracts and the tax reporting of life settlements

Description: In February 2015, the Internal Revenue Service Chief Counsel appointed Alexis MacIvor as the chief of Branch 4 of the Office of the Associate Chief Counsel (Financial Institutions & Products). That branch (sometimes referred to by our readers as the “Insurance Branch”) has seven attorneys who work exclusively on issues concerning the taxation of insurance companies and the products those companies issue. Because of the importance of that branch’s work product to the issues that life actuaries must address every day, the Taxing Times Editorial Board and the Taxation Section Council thought our readers would appreciate the opportunity to meet Alexis and welcome her to the insurance tax actuarial community. Mark Smith of our editorial board recently met with Ms. MacIvor to talk about her background and her new role.