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.

Description: A discussion of: the value of a life insurance contract distributed from a qualified pension plan, IRS industry director directive on the DRD for life insurance separate accounts and IRS actuaries raising new issues on AG 34 tax reserves.

Description: A brief overview of the rules for corporate owned life insurance in section 101j and then summarizes the guidance contained in the IRS notice.

Description: A discussion of the three private letter rulings addressing the tax treatment of group insurance contingent annuity contracts providing guaranteed minimum withdrawal benefits linked to an investment account released by the Internal Revenue Service.

Description: A discussion of Section 7702 and age 100 insured and the need for guidance on combined annuity and long-term care contracts

Description: A look back on the 25th anniversary of the 1984 Tax Act DEFRA and newly proposed regulations and legislation to raise tax revenue.

Description: High on the list of the most frequently asked questions by tax professionals working for life insurance companies is whether a change in reserving methodology or assumptions will be subject to the “10-year-spread” requirements of section 807f of the Internal Revenue Code. This article discusses possible answers.

Description: On Aug. 11, 2011, the Internal Revenue Service IRS released Notice 2011-68,1 regarding the tax treatment of stand-alone and “combination” longtermcare LTC insurance products. The Notice provides interim guidance on certain issues and requests public comment on others. This article discusses that notice and taxation issues related to Long Term Care products, combination products and long term care riders to annuities.

Description: This article summarizes the government guidance for protected cells in the insurance context and the ABA Recommendation, and comments on the Notice and ABA Recommendation in light of traditional notions of equity ownership for federal corporate income tax purposes.

Description: T3: TAXING TIMES TIDBITS