Description: This article is an introduction to the principles of taxation of U.S. owned foreign insurance operations, such as controlled foreign corporations.

Description: Article from The Actuary, December 1986 – Volume No. 20, Issue No. 10 that talks about The Tax Reform Act of 1986.

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

Description: On January 19, 2005, the Treasury Department and the Internal Revenue Service the “Service” responded to a life insurance industry request for guidance on the treatment of qualified additional benefits “QABs” under sections 7702 and 7702A of the Internal Revenue Code through the release of Revenue Ruling 2005-6 the “Ruling”.

Description: The United States district court for the Southern District of Ohio recently issued its opinion in American Financial Group and Consolidated Subsidiaries v. United States. The issue in the case as framed by the Internal Revenue Service IRS was whether Actuarial Guideline XXXIII AG 33 applies retroactively or prospectively to the calculation of reserves for deferred annuity contracts. This article is a discussion of this opinion.

Description: In the environment of discussions about simplifying the tax code for individuals including eliminating many deductions, this editorial raises the question of the appropriateness of eliminating some of the tax benefits of employer benefit plans.

Description: At the beginning of this year, Representative Dave Camp (R-MI) retired from the House of Representatives after 12 terms, the last two terms serving as Chairman of the Committee on Ways and Means. Chairman Camp has played a central role in the national conversation on tax reform, primarily through a series of discussion drafts addressing international tax reform, financial products tax reform, small business tax reform and, most recently, a comprehensive tax reform discussion draft that we explored in a special edition of TAXING TIMES last fall. Kristin Norberg, TAXING TIMES editor, recently sat down with Chairman Camp to talk about his career in the House, the development of the Tax Reform Act of 2014, and some of its potential impacts on the insurance industry.

Description: This article comments on a 1972 paper on the same subject by John Fraser, which made a very careful analysis of the relation between the current earnings rate and the taxable interest. The author builds on Fraser’s illustrative calculations, which showed clearly that there was an optimal spread between the current earnings rate and the assumed reserve interest rate to produce the maximum interest deduction, by including an analysis of the after-tax yield effect.

Description: This article discusses the self-certification procedure for late rollover contributions established by the IRS in Revenue Procedure 2016-47.

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.