Description: The different broad purposes served by the material change concept under federal tax law are outlined. More specific material change and similar issues that are pertinent to particular Code provisions and guidance from the IRS that has addressed those issues are also addressed. In the final part of this article, authors comment on whether any overarching principles can be gleaned that can assist insurers and policy owners in making decisions about whether particular changes can safely be made, and thoughts are offered with respect to future potential IRS guidance that would be helpful as taxpayers navigate these often uncertain waters.

Description: This paper examined two interrelated aspects of federal income taxation of life insurance companies. First, a common-sense approach to the Life Insurance Company Income Tax Act of 1959 was developed. Second, marginal tax rates for Phase III companies was developed.

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 article describes changes to the computation of tax reserves as a result of the Tax Cuts and Jobs Act.

Description: Discusses the importance of making tax-motivated investment decisions regarding one portfolio of a company within the context of the overall tax return of which the portfolio is a part, not necessarily on the tax effect of the portfolio alone.

Description: From the 1960 Transactions Vol. 12 No. 33, this ‘Digest of Informal Discussion’ took place at the 1960 Eastern Spring Meeting of the Society of Actuaries, held in Washington, D.C. March 24-25. The participants discussed the effects of federal income tax on the guarantees involved in annuity considerations, settlement options, pension funds, interest on funds left on deposit, and nonparticipating premiums.

Description: This paper describes the Federal Income Tax FIT treatment of reserves historically. Then it describes Principles-Based Reserves PBR. Finally, it discusses issues in the treatment of PBR under FIT.

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

Description: Article from The Actuary, November 1986, Volume 20, No. 9 on the taxation of insurance companies, Act of 1986. In this article, we concentrate on the corporate income tax, and how the Act affects the taxation of insurance companies.

Description: This paper examines five problematic areas of the Life Insurance Company Income Tax Act of 1959 including the 10-for-1 rule, the deduction for investment income on qualified pension and profit-sharing plans, limitations on certain deductions, policyholder surplus account and shareholders surplus account. A discussion of the paper follows. From Transactions of Society of Actuaries 1976, Vol. 28.