Description: A discussion of the Open Transaction Doctrine and how it was applied to prevent current inclusion of taxable gains resulting from the sale of stock acquired in a demutualization.

Description: This article discusses tax rates used in computing toll charges for closing agreements with respect to corrections under IRS section 7702.

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.

Description: This article provides a short history of the correction procedures previously developed to address compliance failures and the shortcomings of those procedures under sections 101f and 7702, laying the foundation for a sea change in the correction process.

Description: Chairperson's column for the October 2020 issue of Taxing Times with thoughts on the effects of COVID-19 on the Taxation Section.

Description: The article discusses the role played by the "Blue Books" issued by the Congress's Joint Committee on Taxation and the authority accorded them by a recent U.S. Supreme Court decision.

Description: Two relatively recent developments have heightened tax managers’ anxiety concerning the possible disclosure of tax accrual workpapers.

Description: This article discusses recent proposals made by the American Council of Life Insurers related to: life insurance reserves annuity reserves and risk-based capital risk-based capital for investments and accounting for Deferred Tax Assets.

Description: Discusses the achievements of the Taxation Section in 2009 – tax education opportunities, expanded section involvement at meetings expansion of tax content on the SOA exams.

Description: This article summarized the Administration's proposals for new tax revenues in 2010 with respect to insurance and offers the ACLI viewpoint.